ML20072J150
| ML20072J150 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 04/13/1982 |
| From: | Cartin L BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-02, TASK-07, TASK-10, TASK-2, TASK-7, TASK-GB NUDOCS 8306290962 | |
| Download: ML20072J150 (113) | |
Text
{{#Wiki_filter:'J/etc t UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
---------------------------------------x GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CE.NTRAL POWER & LIGHT COMPANY, k METROPOLITAN EDISON COMPANY and :
PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs,
-against- 80 CIV. 1683
- (R.O.)
THE BABCOCK & WILCOX COMPANY and
- J. RAY McDERMOTT & CO., INC.,
E Defendants. *: _______________________________________x Deposition of Defendant THE BABCOCK & WILCOX COMPANY by LUCIUS ROSCOE CARTIN, taken by Plaintiffs, pursuant to stipulation, at the offices of Kaye Scholer Fierman Hays & Handler, Esgs., 425 Park Avenue, New York, Ne'w York, on Tuesday, April 13, 1982, at 11:10 o' clock in the forenoon, before Nancy A. Rudolph, a Shorthand Reporter and Notary Public within l' ( and for the State of New York. 8306290962 820413 PDR ADOCK 05000289 T PDR .
; DOYLE REPORTING, INC.
CERTIFIED STENOTYPE REPORTERS 369 LExtNGTON AVENUE WALTER SHAPIRo, C.S.R. NEw YORK. N.Y. 10017 CH ARLES SHAPIRO, C.S.R. TELEPHONE 212 - 867 8220
2 1
-s - .V~ 2 APPe a'r a n c e s:
KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS. 3 Attorneys for Plaintiffs 4 425 Park Avenue
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New York, New York
.( 5 BY: RICHARD SELTZER, ESQ.,
f Counsel 6 . 7 g DAVIS POLK & WARDWELL', ESQS. Attorneys for Defendants 9 One Chase Manhattan Plaza New York, New York 10 , BY: KAREN WAGNER, ESQ. , 11 and
! ANN MCDONALD, ESQ.,
12 of Counsel O
/)
(_ 13 14 ALSO PRESENT: I 15 DAVID TAYLOR 16 oOo 17 18 4 19 IT IS HEREBY STIPULATED AND AGREED, 20 by and among the attorneys for the 21 22 respective parties hereto, that the sealing,
)
23 filing and certification of the within ! l , s g deposition be, and the same hereby are, N. waived; and that the transcript may be ; 25
3 1 (~D - N_/ - 2 signed and sworn to before any officer authorized to administer an oath, with the
! 3 4
same force and effect as if sworn to before this Court.
.( -j 5 6
IT IS FURTHER STIPULATED AND AGREED that all objections, except as to the form 7 8 f the question, are reserved to the time 9 f the trial. 10 t 11 oOo i 12 13 , g4 LUC I U S RO S CO E CA RT IN, l .
}
15 having been duly sworn by the Notary Public I 16 (Nancy A. Rudolph), was examined and testified 17 as follows: 18 EXAMINATION BY MR. SELTZER: I 19 Q Will y u state your full name and address l l l 20 f r the record? I A Lu i s Roscoe Cartin, 109 Londonberry 21 l C 22 Road, Forest, Virginia. 23 Q What time did you report to work on i I s March 28, 1979? 24 m-) 25 A I w uld have reported normally on the order b
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-- = =
f , 1 Cartin 4 ) v' 2 f APProximately 8 o' clock. Q When did you first hear that there was a 4 transient in progress at Three Mile Island that day? MS. WAGNER: Objection to the question. 5
, Ma. SztTzza: What is the hasis of.your 7, objection?
g MS. WAGNER: There is no foundation that g there was a transient or that he heard about it. 10 You can answer the question. A Sometime early during the day we had heard l gg 1 12 that something was going on at one of the plants. We p. had very little information at that tini,e . 13 , 14 Q When you say "we," is that a royal "we" you 15 mean, Mr. Cartin? l 16 A It was just a general rumor with the general 17 workers in our section that something was going on. 18 Q Now, you have referred to the'" general workers i gg in our section." Are you including yourself in that? 20 A There was a rumor going around that the,re 21 was some transient at a plant. 22 Q All I am asking you is, did you hear the 23
#"" #7 A Yes.
24 25 Q I am trying to find out what you know as
g Cartin 5 ['\ 2 opposed to what others may have known and their telling 3 y u what they know. ' 4 When is the first time that you have a () 5 recollection of somebody giving you any specific 6 information about a transient at Three Mile Island 7 Unit 27 g MS. WAGNER: On or about that day? 9 MR. SELTZER: On that day. 10 A I did attend a meeting in a conference room t 11 where they were trying to get in contact with the plant 12 and I was told there that they had an accident in A ' () g3 progress of some natete at Three Mile island. 14 Q At what time was the meeting in the conference 15 room?
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16 A I would say approximately mid- morning. 17 Other than that, I don't remember exactly. 18 Q .Is mid-morning sometime betwedn 9 o' clock 19 and 11 o' clock? - 20 A It may be somewhere in that time frame, yes. 21 Q Is it your best recollection that the 22 meeting in the conference room was sometime between 23 9 and 11 a.m.? x,
-24 A I d n't know exactly what time it occurred, a My memory 25 as far as the times during that day are
.s
1 cartin 7 2 Mile Island accident on March 28?" and you say there is no foundation there that there was an 3 4 accident on March 28. I consider that the height (. 5 f bstructionism. 6 If this is the way you are going to proceed, let's suspend right now and I will take this 7 g to a magistrate. 9 MS. WAGNER: I will defend the deposition 10 exactly as I choose to. You have to establish a gg basis for the questions you are asking, as you 12 probably know. (V 13 If y u want to terminate th'e deposition, 14 since we waited to begin it from 9:30 -- 15 MR. SELTZER: It is because you saw fit to 16 deliver after 6:30 last night a foot of documents 17 which nobody even had the courtesy to tell us were
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18 on the way. We would have had somebody waiting 19 here for them if we knew they were coming. 20 MS.' WAGNER: I will tell you that I have received documents after 8 o' clock in the evening 21 22 and I have proceeded with the deposition. 23 Nevertheless, we can proceed with this deposition rn t, and I will defend the witness as I see fit. ()
'V 24 25 MR. SELTZER: If this deposition becomes '
\ .
l l l y Cartin 6 l O (_/' 2 very vague. I really didn't pay attention to the hour 3 4 Q All I am trying to understand is when you said it was mid-morning, in your mind were you thinking 5 6 of some time that was approximately between 9 a.m. and 7 11 a.m.? g MS. WAGNER: I think the witness has given 9 y u his answer. He said he didn't know what time 10 it was. 11 Q I am trying to clarify what mid-morning 12 means to you. 13 A That is a reasonable estima'te of mid-morning. 14 MS. WAGNER: You need not adopt in your 15 answer any reasonable answer that Mr. Seltzer 16 gives you. 17 MR. SELTZER: I am not going to proceed 18 with this deposition if you are going to. continue
, 19 to obstruct the progress of the deposition the 20 way you have on these preliminary questions. I 21 e nsider it frivolous and an obstruction for you 22 to make the objections as you have to these very 23 simple questions.
24 I consider you to be an obstructionist if b(~% 25 I ask "When did you first hear about the Three L
. - - ~.-. - - - - ., - -- . - . . . . . , - , - ~ .. , . . - - - . - - . - -
g Cartin 8 D (O 2 a repeat f some of the obstructionist tactics that I have seen used,by Davis Polk in the past, we are _4 going to suspend the deposition now. MS. WAGNER: I object to your 5 (l 6 characterization of Davis Polk's work and I will' 7 continue to defend the witness as I choose. g BY MR. SELTZER: 9 Q Who had convened the meeting in the 10 e nference room that you said took plac at mid-morning gg on March 28, 19797 12 A I was -- my immediate supervisor suggested 13 that I go to the specific conference ro'm. o I do not 14 know exactly who called the meeting,and at that time I 15 accompanied Mr. Bert Dunn to that conference room. 16 Q Who was your immediate supervisor? 17 A Eric Swanson. 18 Q About how many people were in the conference
- gg room for the meeting? -
20 A It wasn't a general meeting. There were some 21 people there. I think it varied with people coming in
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22 and out. There may have been fifteen at one time and in 23 general, when we g t there, there was nothing going on. 24 They were trying to get in contact with the plant and 25 were unable to do so. 3 .
f i Cartin 9 2 Q Was the conference room the same room that 3 8 me POP l e have referred to as the war room or the 4 command center where contact with the plant was ongoing during the afternoon of March 287 ( 5 6 A That's correct. 7 Q How long did you stay in the conference g room after you arrived there in the morning?
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9 A I can't remember the exact time duration. 10 I was there through a phone call that w s received from 11 the plant site. My recollection was it was in excess 12 of about an hour. 13 Q From whom at the site was dhe phone call 14 received? 15 A I don't know the specific individual. I 16 think -- I believe it was a GPU employee from within 17 the control room. 18 Q Was Bert Dunn still in the conference room 19 when that call was received? - 20 A Yes, he was sitting right next to me. 21 Q Is Bert Dunn somebody that you had worked 22 fairly closely with prior to the Three Mile Island 23 Accident? [~h 24 A That is correct.
'%.)
25 Q In addition to being someone with whom w _ _ _ _ _ . _ . , _ . . - - . _ _ , , _ . , _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . , _ _ _ , _ ~ - _ _ _ . _ _ _ _ _ _ _ , - . _ , _ _ _ _ _ . _ _ - ,
, Cartin 10 l
1 you worked closely in your business, is Bert Dunn 2 somebody with whom you had been socially friendly before 3 - . the Three Mile. Island accident? 4 A I had attended several parties and other social occasions with Bert Dunn, that's correct. I 6 would not put him in what I would say one of my best 7 friends. He was a friend. 8 Q While you were in the command center for 9 about an hour on the morning of March 28, you said a 10 e call came in from GPU personnel whom you understood 11 were in the Three Mile Island Unit 2 control room, is
- 12 I
that right? + A There was a call. I don't ~ remember whether , 14 it was initiated by the site or whether it was initiated 15 by.B&W people. . j 16 l Q And you understood that th,e people from 17 . GPU who were participating in the phone call were 18 speaking from the control room? ' ( 19 l A That is my understanding, yes. 20 Q Was the telephone call received over a speakerphone in the command center? ! 22 A Part of the telephone call was on a 23 speakerphone, yes. Q You listened to that part of the ! 25 , f e -v-- -w - --r .------,.~..an . , - - . . - - , , - n.,-. , - - -,- ,- . - - - - . - - - - - - - .n. - - - - - - - -
1 cartin 11 (T ~ k /- conversation, right? A I listened to at least part of the call, yes. 4 1 Q Yo.u listened to the part that was on the 5 speakerphone? 6 A That's correct. 7 8 Q Did Bert Dunn also listen to it? g A Yes. 10 Q Bert was still sitting next to you at the 77 time the phone call was being received over the 12 speakerphone? A g Yes. - 13 g4 Q Did Dunn indicate to you during the 15 aPProximately one hour that you were together in the e mmand center that morning that he had previously 16 l 17 received any information about the Three Mile Island a
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! 18 transient? l gg , MS. WAGNER: I object to the question only 20 insofar as I don't think the witness has testified g that he and Bert were there for an hour together. (_ Q Were y u and Bert there for approximately l 22 l 23 ne hour together? ()
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A I was there at least an hour. I don't l 25 remember the exact time duration. I don't know how
y Cartin , 12
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U' 2 long Bert was there.
, Q Do you have any recollection of his leaving 4
before you left? A I d n't remember. l 5 6 Q Did Bert-Dunn describe to you any other 7 information that he had previously received about the 8 Three Mile Island transient? A No, I do not remember Bert giving me any 9 10 information of that nature. 11 Q Have you ever seen any notes or memoranda 12 that recorded the words or the substance of the 7r k., 13 telephone call betGeen B&W and GPU that'you have just 14 referred to? 15 A No. 16 Q I.take it in the course of yo"r u preparation 17 you did review notes that were created on the day of the 18 accident, is that right? 19 MS. WAGNER: Objection. - 20 MR. SELTZER: You may answer. 21 A I did not retain any notes that I took. 22 Q I wasn't referring to notes that you took. 23 I was asking you did you, in the course of your 24 preparation for this deposition, review any notes such 25 as Wandling's notes recording information that was .
1 Cartin 13
% /~ received on the day of the accident?
2 A No, I did not. 3 4 Q Y u didn't review any notes that related to information received on the day of the accident? ( 5 6 MS. WAGNER: I object to that question 7 because there are an awful lot of documents g that indicate such information. I would prefer g if you would show the witness specific documents. 10 I will not allow him to answer co cerning what it documents he saw concerning the accident. I would 12 prefer you show him a specific document. b d 13 MR. SELTZER: There aren't'that many 14 documents that were created relatindJ to what was 15 being received in Lynchburg from the Island on 16 the day of the accident, and what I am referring to., 17 I am asking Mr. Cartin whether he recalls reviewing i 18 any of_that. - 1 19 A I did not review any documents- that 20 generally outlined in specifics an exchange of information 21 that occurred on that day. 22 Q To the.best of your recollection, what was 23 the information that was received from Three Mile Island 24 in the telephone conversation received on the morning 25 of March 28?
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g Cartin 14 N" 2 A Generally B&W requested some plant parameters 3 a genera , status report concerning the condition of the 4 plant. The most rememberable piece of data were the 5 pressure and temperature conditions which we quickly { 6 determined to be superheated. We looked those up 7 immediately with the steam tables that we had available g to us at that time. g Q When did you look it up? 10 A Immediately. After I heard..the pressure 11 and temperature conditions over the telephone's squawk 12 box, I immediately looked them up in the steam tables to 13 determine the state of the fluid. 14 Q What, if any, other information did you get? 15 A The other information I don't remember in 16 detail. l 17 Q I wasn't asking only for what,you remembered 18 in detail. i 19 A Th'ey asked for general plant status, general 20 indicators including pressure and temperature conditions, 21 probably level and other indicators relative to the steam 22 generator. l 23 Q You referred to level. Level in what 24 P i ece of equipment? ! 25 A Level is generally measured in the l
, - - - - - + - -- m
y Cartin 15 O- 2 Pressurizer as well as the steam generator, are the two 3 m st relevant level measurements. - 4 Q Do you believe that B&W asked for a report 5 n level in the pressurizer? ( 6 A I don't remember specifically whether that 7 parameter was requested. g Q Do you remember whether B&W requested 9 information on level in'the steam generators? 10 A Not specifically. I would resume that 11 those are normal parameters that would be asked for by 12 any engineer asking for plant status. [/h (._ 13 Q When you use the word "those," you mean 14 pressurizer level and steam generator level? 15 A Yes. 16 Q Did you and Bert Dunn discuss the fact that the pressure and temperature data received ( 17 l 18 corresponded to superheat? l 19 A Yes. , 20 Q Did the ensuing discussion of the superheated l~ , 21 conditions lead to a recommendation to have Met Ed (. 22 charge 400 GPM of high pressure injection? 23 A I remember the discussion led to a () 24 recommendation to start HPI. As far as numerical 25 value, I don't recall. l I
y Cartin 16
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2 Q Are you aware that other people's 3 ree llections of the first time that superheat was 4 identified at Lynchburg placed that recognition in the afternoon of March 28th rather than the morning? { 5 6 A No, I am not aware of that fact, but I 7 stated previously I was not specifically aware of the 8 timing of the conversations that took place that day. g Q Are you saying when you were not 10 specifically aware of the timing, are you indicating that 11 it is conceivable that the telephone conversation that 12 you have just described took place in the afternoon of (~ (T/ 13 March 28 and not the morning? 14 A That is conceivable, yes. 15 Q Bert Dunn testified that he went to the l . 16 lunchroom and played cardseduring lunch on March 28, l
- 17 1979. The only reason I am telling you that is Bert l
[ 18 in his testimony was very certain that he "did not realize 19 there was anything serious happening at Three Mile l l 20 Island until the afternoon'because he had a ' clear l l 21 recollection of going to the lunchroom and playing cards 22 during lunch, so I am not asking you a frivolous i 23 question in asking you do you recall what you did l i 24 during lunch that day-25 MS. WAGNER: I would like to object to
f 1 Cartin 17 2 the preface of the question. You may answer the question as to what 3 4 you were doing during lunch that day.
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' A Id n t recall.
(; 5 6 Q Do y u sometimes play cards during lunch? 7 A Very seldom. 8 Q How much time in total did you spend in the 9 command center on the day of the accident? 10 A I don't specifically recall. I don't remember 11 the actual time span. I was there during one telephone 12 call with the site. The actual number of minutes or 13 hours, I don't actually recall. 14 Q Other than the period of approximately one 15 hour that you recall being in there, did you return to
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i 16 the command center again during the daylight hours of i 17 the day of the accident? 18 A It is possible that I could have been in and 19 out. 20 Q Do you have any recollection of going in 21 more than once? l 22 MS. WAGNER: Mr. Cartin, let me instruct 23 you that Mr. Seltzer is asking for your 24 recollection. He is not asking you to speculate 25 about what you did on that day. Just give him
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I
cartin 18 n 3 your best recollection of what you did on that 3 - A I do not really remember how many times I 4 ( 5 was in the conference room,whether it was once or more than one time. 6 7, Q That certainly' narrows it down. 1 8 Was the telephone call still in progress g when you recognized from the steam tables that the 10 temperature and pressure conditions that had just been 17 relayed corresponded to -supe rhe at? 12 A Yes. 13 Q Did you do anything to step up to the 14 microphone to alert the people at Three Mile Island that 13 you had identified superheat conditions? 16 A We made a general announcement to the people 17 in the room of our conclusion. 18 Q "We" being you and Bert? " 19 A Bert and I. I myself did not make an 20 direct, give any dire t inp'u t to the plant. 21 Q Do you have any recollection of anyone else 22 immediately -- in other words, during that telephone 23 e nversation that was ongoing -- telling the plant that 24 B&W's engineers had identified superheat conditions? 25 A I d n't really recall.
, , -n. , . - ~
y Cartin 19
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2 Q Did there come a point in time after you .i 3 and Bert Dunn had identified superheat conditions that 4 y u related the existence of superheat to a possibility ( 5 fc re uncovery or imminent core uncovery? 6 A We reached -- we identified that possibility 7 almost immediately. 8 Q It is a fact, is it not, that you and Bert 9 Dunn communicated that possibility to the people who 10 were in the command center? e ig A Yes. 12 Q It is also a fact, is it not, that many of (~N , k- 13 the people in the command center did not immediately 14 appear to understand how it could be that the core could
- 15 be in imminent danger of uncovering?
. 16 MS. WAGNER: I object to the question only 17 insofar as you are asking him whether they 18 couldn't figure out how it got in t$ere or the I 19 symptoms indicated that it was in there. I am 20 not sure how you are asking the question. 21 MR. SELTZER: Let me try and take it in l C 22 smaller steps. 23 Q First, you and Bert Dunn heard tenperature ; ( 24 and pressure conditions over the telephone, is that 25 correct? i l L_
y Cartin 20 rm U 2 A That is correct. Q Then you compared those temperature and 3 4 pressure conditions with a steam table, right? A That.s correct. g7 s 6 Q In 1 king at the steam table, you 7 identified that convergence of temperature and pressure
, g as corresponding to superheat?
s A True. 9 10 Q And it would correspond to superheat at the 17 point where the temperature and pressure was being 12 measured? i N
' 13 A That's correct.
4 14 Q You believed you had hot leg measurements, , 15 right? 16 A At the time, yes. 17 Q S that from the data you had received and i 18 the information you had developed from the~ steam table, i I 19 you concluded that there was superheat at least in the l i 20 Three Mile Island Unit 2 hot legs? 21 A Yes, in that region there was existing C. superheated steam. i , ,22 j l l I !' 23 Q Y u and Bert Dunn announced to the people i i 24 who were in the room that there was superheated steam l l 25 e nditions in the Three Mile Island reactor coolant i
1 Cartin 21 I-' s) 2 system, right? A .That's correct. 3 4 Q You and Bert Dunn also announced to the pe ple in the room that the existence of superheated ( 5 6 steam conditions in the hot legs indicated a possibility 7 of imminent core uncovery, isn't that right? g A We indicated that a potential cause for 9 those conditions could be core uncovery. , 10 Q What do you mean "a potential cause"? 11 A It could have superheated steam created when 12 you uncover the core. s
\- 13 Q It is a fact, isn't it, that people in the 14 room let you know that they didn't understand how there 15 could be core uncovery while the pressurizer was 16 indicating full, isn't that right?
t 17 A I do not remember any general; disagreement. 18 I do remember that we drew some pictures t'o visualize 19 the phenomena. 20 Q Well, I didn't ask you whether there was 21 general disagreement. What I would like you to focus 22 on is, isn't it a fact that there were people in the 23 room who indicated verbally that they didn't understand 24 how there could be core uncovery or possible core 25 uncovery at the same time that the Three Mile Island
g Cartin 22
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2 pressurizer was indicating solid conditions? A I d n t remember that, no. 3 4 Q Do y u remember that there were people in the room who did not understand how the Three Mile ( 5 6 Island core could be uncovering or be in imminent 7 danger of uncovering, given the plant parameters? g MS. WAGNER: I would like to just object. 9 Are y u assuming now, given whatever 10 they knew without wanting'to spec,1fy what they f St 11 did know at that time? - 12 MR. SELTZER: Yes, given whatever they knew 13 MS. WAGNER: You are not limiting it to 14 just this pressure and temperature that we 15 discussed? 16 MR. SELTZER: Correct. 17 (Continued on Page 23) , 18 19 20 22 23 o
~4 QT 25
I 1 1 Cartin 23 s
\ / 2 Q Let me tell you, Mr. Cartin, we come to 3 your deposition having taken a lot of other discovery.
4 About five or ten other people who were in the command 5 center at the time of.the telephone call you related
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6 have already testified. They have described things 7 such as the fact that Wandling was taking notes, that 8 Wandling was writing on a blackboard at one end of 9 the room so that plant parameters were on 10 continuous display for people in the ro m and I don't 11 want to protract your deposition unnecessarily by 12 reviewing things that are not apparently in dispute
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(_,) 13 so when your counsel-refers to all the' parameters that 14 people were aware of, yes, I mean all the~ parameters 15 that people in the room were aware of from 16 communications that had arrived during th'e day, 17 including information that had been written on the i 18 . blackboard in the room. 19 The question is, isn't it a fact that 20 there were people in the command center who indicated 21 orally that they didn't understand how the core could 22 be uncovered or in imminent danger of uncovering in 23 light of the plant parameters that they were aware of? 24 A Would you repeat that again, please? O(~T 25 Q Isn't it a fact that there were peopic in
1 Cartin 24 1
\/- 2 the command center who stated orally that they didn't 3 understand how it could be, as you and Bert Dunn had 4 said it could be, that the core was either uncovered 5 or ir. imminent danger of uncovering given the plant
{i 6 parameters that were believed to exist at the same 7 time? 8 First, let me ask you, do you understand 9 what my question is? 10 A I understand your question t I remember 11 describing to some people why that could occur. Whether 12 that was because they didn't understand or were just (')T (, 13
- asking for an illustration of the phenomena involved, 14 I cannot attest. It was very obvious to me and i
15 Mr. Dunn as to a core uncovery condition. I did not 16 feel that people did not believe us. 17 Q Did you explain to anybody, in words or 18 diagrams, how core uncovery could exist at the same 19 time that the pressurizer was full? - 20 A I recall drawing some simple sketches 21 illustrating how steam voids could form and exist in 22 the system with a significant amount of water present 23 in the pressurizer. 24 Q Were you explaining that particular fact s 25 because somebody had asked you to explain how that could
1 Cartin 25 p) s_ 2 happen? 3 A_ I d n t remember the exact request but I 4 do remember going through an explanation, yes. ( 5 A Q What is the diagram that you recall drawing? 6 It was a simple sketch of a reactor coolant 7 system, a reactor. vessel, a generator, some pipes and 8 the pressurizer. g Q Would you be able to reconstruct it now? 10 MS. WAGNER: Mr. Seltzer, I am going to gg object to his trying to recreate something 73 because I don't think he can exactly remember (* 13 what he did. 74 MR. SELTZER: I wish you hadn't told him 15 an answer before he had answered. . 16 Q Would you be able to recreate that now? 17 A I am not sure that I could recreate an 18 exact copy of what was done on the board.' I. 19 Q Do you think you would be able to do it l 20 r ughly, approximately what you had put on the board? 21 A only in very simple terms.
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22 Q I w uld like you to do in simple terms the t 23 best that you can to recreate what you had put on the 24 blackboard in the command center on March 28th.
'u) 25 MS. WAGNER: Mr. Seltzer, I am going to ,
I 1 Cartin 26 2 object to that. The witness doesn't have a copy 3 of that with him. He can describe to you what 4 he did. This is a time for testimony. 1;e is 5 not an artist. I think he can tell you generally ( 6 what he did but I don't think it is appropriate 7 to tell him to draw a picture and then have him 8 tell you that this is the picture that he drew 9 in the boardroom. 10 MR. SELTZER: Whether he is an-artist or 11 not is not the issue. In the command center, as 12 you call it, the war room, he did put a drawing
)
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13 on the board. He has said that h'e believes in 14 simple terms he would be able to reconstruct 15 what it was that he put on the board in the war 16 room. 17 We have no other photograph or facsimile 18 reproduction of it so it is probative to see what 19 it is and I really think the fastest way to get 20 on with it is for him to draw it. I don't think 21 that words can adequately depict what a simple 22 drawing will. 23 MS. WAGNER: The reason we don't have 24 anything is because things on blackboards very (~)S 25 seldom remain forever. If we had it, we would
1 cartin 27
-s 2 have produced it.
3 MR. SELTZER: I am not protesting that you 4 failed to produce something. 4 5 MS. WAGNER: I will object strenuously to ( 6 the introduction of any such document into this 7 testimony even for identification. However, I 8 will allow him to do it based on my objection 9 and we will discuss it at a later time. 10 You can go ahead and do it,. Mr . cartin. 11 A Probably no more sophisticated a sketch 12 than that. rb k)m 13 Q Are you saying that on the' day of the 14 accident you probably drew no more sophisticated a 15 sketch than this one? 16 A That's correct. 17 Q With this sketch on the blackboard, what 18 did you describe? 19 A I don't remember the specificities of my 20 conversation. I tried to give an explanation to -- I e 21 don't even remember the people involved -- of why a 22 steam void can exist, possibly uncover the core with 23 some water in the pressurizer. I just basically drew
/~N 24 some little bubbles here and there and said they can k_)
25 exist and say the pressure would be -- generally the
I 1 Cartin 28 C)
~#' 2
- system would be acting as a pressurizer. It wouldn't 3 be natural for the water to drain from the pressurizer.
4 Q What did you understand on March 28th was 5 the explanation for how water could be held up in the ( 6 pressurizer while there were steam voids below it . 7 in the reactor vessel? 8 A Well, the potential there for an open PORV 9 could cause water to migrate to the pressurizer. The 10 PORV should it be closed, the water cogld stay there 11 if steam was created in the system because the system 12 as a whole would be acting as a pressurizer. Pressure (3 (_) 13 in the system would be controlled by tNe amount of 14 volume the steam occupied. 15 Q Taking your second assumption that the 16 pilot operated relief valve was closed, why,wouldn't 17 the water in the pressurizer drain down into a partially
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18 vacated or partially empty reactor vessel?
, 19 A I don't r,emember my exact expl~an a tio n at 20 that time but it depends on many factors. Pressure 21 distribution in a system is one.
22 Q As you have drawn the pressurizer, you
-23 didn't put a loop seal in, did you?
24 A In that particular sketch, no. 25 Q In fact, in the B&W design for nuclear
29 1 cartin O(~'% 2 plants, there is a loop seal between the pressurizer 3 and the hot leg, right? 4' A I cannot say that's a general design 1
- 5 feature.
( 6 Q. Are you aware that some B&W plants do have 7 a loop seal adjacent to the pressurizer? 8 A I have heard that that was on at least one , 9- P lant, yes. 10 Q Which plant? 11 A TMI. 12 Q TMI-27 rs (_) 13 A I remember it being a quesElon raised 14 concerning that loop seal for TMI-2, 15 MS. WAGNER: Could I have that last answer i 16 read back. l 17 (Record was read back.) . 18 Q In other words, you have heard the design 19 of the Three Mile Island Unit 2 pressurizer includes a 20 ' loop seal? 21 A Yes. [ - 22 Have you ever heard of a B&W 177 fuel Q 23 assembly plant that did not have a loop seal attached
/~)
(.,/ 24 to the pressurizer and if so, could you tell me which 25 plant you heard that for? I m,. -- - -,.n,- , , , , - - - ,, - - - - - , . . , ---,-,,n. . . - - , , , , , - , , - - , , - _ - , - - - - - -
. - - . . . . . _ - . -. . . __ - = . -
7_, 1 cartin 3o O- 2 A I am not aware of the pressurizer 3 arrangement on any other plant and the pressurizer 4 surge line. 5 g was it your understanding on March 28, 1979 (( 6 that water could be stopped up in the pressurizer so 7 that there would be a substantial amount of water in 8 the pressurizer while there was voiding in the f 9 reactor vessel? i 10 A I remember at that time under certain 11 circumstances that was deemed a possibility. At that 12 time we didn't have a lot of data as to exact condition i (s (_) 13 of the plant and exactly what had taken place. We were 14 speculating on the limited amount of data set that 15 we had, a 16 MS. WAGNER: Mr. Cartin, I think 17 Mr. Seltzer is generally asking you what your ,
~
18 understanding was of various physical facts, 1 19 sometimes in connection with what happened that 20 , day and sometimes just in general, so you should s 21 try to -- I think that was his last question 22 rather than what you specifically told him that 23 day, so you should listen carefully to what he 24 is saying. 25 Q I would like you to limit yourself to a
, , , , - - - . , - - - - - - - , , - - - - -a - - , , ~ , , , - . - - - , , - - - - - - - , - - ,
. - , - . . , . . , -n -- . ,
t 1 Cartin '.31
'O 2 situation where all of the relief valves are closed on 3 the Pressurizer and where there is voiding in the 4 reactor vessel.
5 What, to the best of your recollection, ( 6 did you understand on March 28, 1979 could physically 7 cause water to remain in the pressurizer under those 8- conditions? 9 MS. WAGNER: Just to make this clear, 10 Mr. Seltzer, I take it you want is general 11 understanding on that day, not as relates to 12 whatever facts he knew about TMI on that day,
~
- 13. is that right?
14 MR. SELTZER: Right. 15 A In general, you could have water exist in 16 the pressurizer or water be caused to go to the 17 pressurizar..If you'are creating steam and that steam 18 is occupying the upper regions of the loop, that steam 19 can' displace the water into the pressurizer because 20 there is a pressure distribution and the water will 21 remain there. If the pressure is higher at the inlet 22 of a surge line, it will tend to go to the point of the 23 lowest pressure. 24 Q. Are you saying that -- O. 25 A If I have steam being created in the core
1 Cartin 32 ('I A-s 2 and it wants to occupy this space, any water that can i 3 exist in here can be displaced into the pressurizer. 4 Q In order for the c o r'e to uncover, the hot 5 legs have to empty off water, right? { 6 MS. WAGNER: Mr. Seltzor, I assume you #are 7 asking for Mr. Cartin's understanding at or 8 about the time of the accident rather than his 9 current u'nderstanding? 10 MR. SELTZER: P.ight. p 11 A I would assume at the time of the accident 12 that I would have expected the hot legs to have a 13 significant amount of voiding for the 'c o r e to uncover. 14 Q You have drawn a diagram which we will 15 mark as GPU Exhibit 492 which shows the hot leg inlet 16 and outlet above the top of the core, right? 17 A The hot leg outlet -- 18 Q I'm sorry, the hot leg outlet'and cold leg 19 inlet are both above the top of the core, isn't that 20 right? 21 A That's true. 22 Q And that was your understanding of the 23 relationship especially between those inlet and outlets
/'T 24 and the core on the day of the accident, right?
'b 25 A That's correct.
s 1 . cartin 33 N ' 3 s \_/
)
2 Q If the le' actor coolant pu:nps are off, isn't
. .s .N
- s, s 3 it a fact that for thehe to be core uncovery all of s
4 the water would have to have drained out of the hot
+
-.~
( 5 legs? x s s t 6 Ms. WAGtBR: Again-you are asking for 7 Mr.'Cartin's understanding on the day of the w' g . , - g accident? , g 1 9 MR. S3LTZER: Yes, that's all I am focusing
~ . ,
10 on. t s s 11 Q s, I will let you know when I am moving away
,N w
12 from your Mnde'rstanding as of March 28, 1979. 1 N 2 [ (O) 13 A T h'a., w a t e r in the hot log would seek a low ,
- x -
s- , 14<' elevation, preferentially the reactor vessel.
, b ^
15 Q Just"so a judge can understand this, you are 16- saying that before'there could be core un"covery, the s . s 17 .If. quid' water in the hot le g s ., wo u ld drain out of the N s. s 1r ' hot legs? A ,) *
, s - .s 19 A I would' expect- - -;-- a- majority of that water N ,
, ). s
\'g to have dt'ad'ned to the reactor vosse$., 2 yes'.
~
21 Q N w, you have t used,the' word " majority" N a s 22 which just means'm6re than 50 percent which would s e i .
- 23 s create in somebody's mind _the possibility that as much s . _
s as 49 percent of the liquid inventory could still be O
\J
- 24 25 up la the. hot legs. That is not correct, is it?
's' ' x '
.m g
.\_. _ _
I 1 Cartin 34
/7 - 2 MS. WAGNER: Could you just ask a question, 3 Mr. Seltzer?
4 Q Yes, isn't it a fact that before there could 5 be core uncovery, the hot legs will be filled with ( 6 steam and whatever water there is in the reactor coolant 7 system outside the pressurizer will be below the level 8 of the top of the core and, Mr. Cartin, I am asking you 9 that for a situation where the reactor coolant pumps 10 are off? 11 MS. WAGNER: And you are making no other 12 assumptions as to what tine it is or what else C) (_j 13 is going on or anything else?
~
I' find your question 14 confusing, Mr. Seltzer. 15 If Mr. Cartin can answer it, he can, but
~
16 I am lost. 17 A For the core to uncover, I would have 18 expected that the hot legs would have been essentially 19 void of water. There could be water in other locations 20 of the RCS. 21 Q Locations other than the hot legs, right?
' 22 A The steam generator, cold leg.
23 Q But not the hot legs, right? Q
\_/
24 A Right. 25 MR. SELTZER: I would like to mark
l 1 Cartin 35 A(~) i 2 Mr. Cartin's diagram as GPU Exhibit 492 for 3 identification. 4 MS. WAGNER: I will note again an objection 5 to this entire procedure. ( 6 (Diagram marked GPU Exhibit No. 492 for
~
7 identification, as of this date.) 8 Q The drawing that you have created as GPU 492
. 9 which you say is similar to the drawing you put on the 10 blackboard is a simplified representation of part of a 11 B&W 177 plant, right?
12 A That's correct. O) (_ 13 Q some of the simpleficationbthat you have 14 made include the fact that instead of showing both 15 hot legs, you have just shown one hot leg, right? 16 A That's correct. l 17 Q Instead of showing four cold , legs and four 18 reactor coolant pumps, you have only shown one cold leg j . 19 and one reactor coolant pump, correct? l i 20 A That's correct. l l 21 Q The position of the steam generator is { - 22 intended by you to show its position in a 177 lowered
- 23 loop plant such as Three Mile Island Unit 2, right?
/h 24 A That's correct.
V 25 Q Could you indicate on that diagram what is l
1 Cartin 36 2 the pressurizer? 3 MS. WAGNER: The record should reflect the 4 witness has so indicated. 5 Q You wrote PZR in the pressurizer? ( 6 A That's correct. 7 Q Could you indicate by writing RCP where the f
- 8 reactor coolant pump is?
9 A (Witne s s complies.) 1 10 Q Could you indicate where the steam generator 11 is? 12 A (Witness complies.) 13 Q Could you indicate what is'the hot leg? 14 A (Witness complies.) , 15 Q You have put an HL where the hot leg is? 16 A That's correct. l 17 Q Could you put a CL where the cold leg is? l
~
I 18 A (Witness complies.) 19 Q Could you write the word " Co r e-" with a line 20 to the area that is the core? l !. 21 A (Witn e s s complies.) 22 Q The core sits within the reactor vessel? 23 A That is correct. Could you write RV for reactor vessel? (~} v 24 Q 25 A (Witness complies.) w----------m---wy., w *
' ---.---,-.e_c .- -wt--+---v-
1 1 cartin 37 fh N /. 2 Q You also put an arrow in the hot leg. That 3 indicates the direction of flow of coolant, is that 4 right?
. 5 A That could be an indicator of that. I was 6 trying to make a distinction between the primary and 7 secondary side only.
8 Q Could you explain, please, what your 9, understanding was on the day of the Three Mile Island 10 accident of how water could be held up in the e 11 pressurizer under the following conditions: All the 12 pressurizer relief valves are closed and there is only (3 g ,) 13 steam in the hot legs, and the RCP's are off? 14 MS. WAGNER: Is it my imagination or 15 haven't we had this testimony several times 16 already? 17 MR. SELTZER: I think we have gotten very 18 close to it and I said I wanted to define some 19 terms on the diagram before I asked-the question. 20 I think I withdrew the question the l'ast time. 21 MS. WAGNER: I thought he answered it 22 before but you are welcome to answer it again. I l . 23 A I don't remember the exact explanation i rT 24 I gave in the TMI -- in the conference room or even 25 if that was a topic of explanation with my sketch. We i {
1 1 cartin 38 O
~s -
2 talked about core uncovery. I may have illustrated 3 that with the sketch. I would presume that if you had 4 water within the pressurizer, it could be prevented 5 from draining if the pressure in the local hot leg 6 region was higher than that that existed in the 7 Pressurizer. 8 Q If all that there is is steam in the hot 9 '~ leg, why wouldn't the water in the pressurizer simply a 10 drain out into the hot leg? 11 A You have to take a detailed look at the 12 geometry to make any evaluations of that nature. 13 Q What geometry are you referring to? 14 A Specific layout of the hot l'e g , locations 15 of the nozzles, layout of the pressurizer and surge 16 line. 17 Q Am I correct that it was your understanding 18 on the day of the accident that the hot lbgs would 19 drain off water before the core uncovered assuming 20 the reactor coolant pumps are off? 21 MS. WAGNER: Mr. Seltzer, the witness has 22 testified to that several times. l I l 23 A Yes. { i l ("
\-
24 Q Once they have drained off water, isn't l ~ 25 it a fact that the steam that remains in the hot legs l i { t
1 1 Cartin 39 f~%
\
N' l 2 will become superheated? 3 A For the steam to become superheated, it 4 must be heated by a heat source. Just because a system 5 is filled with steam does not automatically make it ( 6 superheated. 7 Q Isn't there localized heating from the 8 piping? 9 A There can be. 10 Q Did you understand on March 28, 1979 that 11 there could be superheat in the hot legs due to tra') ped 12 steam voids there before there is core _uncovery?
/O 'N _ 13 A You can superheat steam due to compression 14 if you are trying to refill the system. If you take a 15 trapped steam void and compress it, yes, you can create 16 superheated conditions.
17 Q I would like to clarify something. When 18 you and Bert Dunn first recognized that there was ( 19 superheated steam in the hot lege, did the two of you 20 reach the conclusion that the core was already uncovered? 21 A My conclusion at the time was that, yes, l (_ 22 core uncovery was in progress. l 23 Q Did you discuss that with Bert Dunn? 24 A I so indicated my conclusion to hLn . 25 Q In addition to the explanations that you I
1 Cartin 40 f~)/- 2 were doing in conjunction with the drawing on the 3 blackboard, was Bert Dunn doing anything to explain 4 how the indicated superheat conditions indicated ongoing 5 or impending core uncovery? g 6 A I really don't remember what Mr. Dunn was 7 doing at the time. 8 Q Can you tell me the names of any of the 9 people that you were discussing these facts with? d 10 A Today I do not remember the exact 11 individuals. 12 Q Do you have any recollection or belief as 13 to who they were? 14 A I really do not remember. 15 Q Do you have'any hunches or best guesses 16 as to who they were? 17 MS. WAGNER: I object to the question and 18 I will advise you not to guess. Give Mr. Seltzer 19 your best recollection. - 20 A I do not remember. 21 Q In understanding what you mean by saying L 22 you do not remember, does your mind draw a complete 23 blank on who the individuals were that you were talking 24 to or is it you just don't have a high degree of 25 certainty about who they were?
1 Cartin 42
' ("%i
\~ '
2 A Right now I don't even know anyone to make 3 a guess of who that could be. I just do not remember. 4 Q For how long were you explaining to people l 5 how the system operated and how the temperature and 6 pressure which you had just heard over the telephone 7 could be evidence of core uncovery? 8 A I don't remember the exact time frame. I s would say .it is a very short time period. 10 Q Who, if anyone, suggested what B&W chould 11 do as a result of the discovery that you and Dunn had 12 made? 13 A I don't remember who made specific 14 suggestions that day. 15 Q Was any suggestion made as a result of 16 the conclusion reached by you and Bert Dunn about 17 superheat and possible core uncovery? 18 A I did raise the question of whether HPI was 19 on. We asked what was the status of the high pressure 20 injection system. 21 Q Who did you ask? L 22 A No one in specific. We just asked the
- 23 general question of who knew.
24 Q Did you get an answer? 25 A I remember getting an answer but I do not y %- m -g qq q- . - - - -- - -y-e4, +-
I 1 Cartin' 42 (~\ 2 remember what the answer wa'. s 3 Q What, if any, other action was taken as a 4 result of the deductions made by you and Bert Dunn 5 about superheat and possible core uncovery? ( 6 A My memory says that B&W recommended that 7 they initiate high pressure injection. I was not a
- i. 8 there -- I don't believe I was there at the time that 9 recommendation was actually transmitted.
10 Q Were you there at the time that the 11 400-gallons-per-minute recommendation was formulated? 12 A I don't remember participating in the [\ (_/ 13 formulation of that number. 14 Q Do you have a recollection of' 400 GPM being i' 15 the suggestion that B&W was going to make? 16 A I have heard that number but I do not l \ l 17 remember hearing that number that day. 18 ,Q, Based on what you knew on March 28, 1979 19 about the function of high pressure injection and based 20 on what you had deduced were the conditions in the 21 Three Mile Island reactor, are you aware of any good l 22 reason why B&W should not have recommended turning HPI 23 on full throttle instead of merely 400 GPM7 24 A I think the conditions indicated that HPI 25 is required. There may be good reasons why full flow t
t 1 cartin 43 ( N - 2 may not be desirable but that would require some 3 additional knowledge of the, actual conditions when that 4 recommendation is made. (- 5 Q Well, I am telling you that the reactor 6 coolant pumps are off and that you have received the 7 temperature and pressure readings which you received. 8 I am also.asking you to take as a given your conclusions 9 that the hot leg has emptied and that the core is either 10 in danger of uncovering or is already yncovering and 11 I am asking you, can you give ms any good reasons that 12 you were aware of on March 28, 1979 why high pressure O)
\) 13 injection should not be recommended to'be turned on 14 full throttle?
15 MS. WAGNER: Mr. Seltzer, I have to object 16 to your question insofar as it excludes information 17 which may have been known to him at the time which 18 has not been the subject of testimony in this e 19 deposition. , 20 MR. SELTZER: He can bring that out. .That 21 would be a reason. 22 MS. WAGNER: And I advise you, Mr. Cartin, I 23 Mr. Seltzer is calling for your recollection and l 24 your understanding on the day of the accident, ['~}/ s_ 25 not your speculation today.
I 1 cartin 44 b) '- 2 In other words, with a core that is either Q 3 uncovering o.r in imminent danger of uncovering, can you 4 recall any reason why B&W wouldn't turn HPI on full ( 5 throttle? 6 A No, but 400 GPM may have been an adequate 7 level of'HPI flow to recover the core for a plant in 8 that condition. 9 Q You have testified that you believed that 10 the superheated condition in the hot leg indicated that 11 there was already ongoing core uncovery, right? 12 A I testified that that was a possibility (x_ 13 that I had identified in my mind, yes.
~
14 Q How much of the core did you think had 15 uncovered? 16 A I don't remember at that point in time. 17 I don't remember making that sort of conc,1usion. 18 Q Do you think you had any data'available 19 from which you could have made any reasona'ble conclusion 20 as to how much of the core had already uncovered? 21 A You can make some inference from the level (. 22 of superheat but it requires some guessing. 23 Q What was the level of superheat? [T 24 A I do not remember.
\_)
25 Q Do you remember what the temperature and
1 cartin 45 I
\_ .
2 pressure coordinates were? 3 A I do not remember.' 4 Q Do you have any idea? 5 A I do not reme,mber. 6 Q Do you remember whether it was just barely 7 into the superheat range or was it substantially above 8 saturation? 9 A I don't remember the magnitude of the i 10 superheat. t 11 Q Had any of your prior experience at B&W 12 taught you that when there was ongoing core uncovery O. that-it would be proper to turn on HPI'less than halfway
- 's_) 13 14 rather than turn it on full? '
15 MS. WAGNER: Mr. Seltzer, I am going to 16 object to your question insofar as"it seems to 17 ' imply some limitation in whatever B&W recommended 18 on the day of the accident. - 19 M,r . Cartin -- - i 20 MR. SELTZER: No, it doesn't. It absolutely 21 doesn't. I reject that suggestion. 22 MS, WAGNER: Well, I am going to make the 23 objection anyway. Mr. Cartin has testified that (~ 24 he was not a participant in the decision as to G}'. 25 how many gallons per minute should go into the l i l I- _ _ , - . _ . _ _ . . -. . , , _ _ __ . . _ , . _ . _ _ . . . , . ___.7 . _ _ . _
1 Cartin 46 2 reactor at TMI. I don't think it is proper to 3 ask him questions based on a limitation that you 4 are drawing from other people's testimony with j g- -5 which he is not familiar. 6 Q rou may answer the question. 7 MS, WAGNER: Could we have the question 8 repeated, please. - 9 (Record was read back.) e 10 A Under those conditions that you identified, 11 it would be desirable to have as much HPI as possible. 4. 12 Q And by "as much HPI as possible," that would 13 mean turn it on full throttle? 14 A If the core is really uncovering, the more 15 HPI you have, the shorter time the core would be 16 uncovering. 17 Q And in order to recover the core in a shorter 18 period of time as possible, HPI should be' turned on full 19 throttle? - I 20 A The larger the HPI flow, the shorter the I 21 time of core uncovery. l (J 22 Q Have you ever discussed with anyone why 23 B&W's recommendation on March 28, 1979 was only for i l l 24 HPI to be turned on at a flow rate of 400 gallons per 25 minute? l
I-1 Cartin 46A I
'2 A I only remember discussing it with. counsel.
3 (Whereupon a luncheon recess was taken 4 j .4- at 12:30 p.m.)
'( 5 ,
6 7 4 i 8 , i . , 9 i 10 l t i 11 1 ! 12 I . j 13 i 14 h ! 15 I 16 i 17 o . l
~
! 18 i i j 19 ! 20 I I 21 b 22 23
- 24 i -
l 25 I l t ! .-- . ,-- ...._. . - _ - - - . . _ _ . .-~ _ -.-
I 47 1 1
\/ 2 A F T E RNOON S E S S ION 1:50 p.m.
3 4 L U C'I U S RO SCO E CA RT I N, l, 5 6 havin9 been Previously sworn, resumed and 7 testified further as follows: g EXAMINATION (Continued) g BY MR. SELTZER: 19 Q Mr. Cartin, you are aware t, at your 11 testimony this afternoon continues to be under oath, 12 are you not? 13 A I am aware of that, yes. 14 Q Have you given any other testimony under 15 oath with regard to the Three Mile Island incident? 16 A No. 17 Q Have you had any transcribed interviews 18 that have had anything to do with the Three Mile Island 19 accident? - 20 A No. 21 Q Have you reviewed any NRC notes of an C 22 interview with you that was conducted after the Three 23 Mile Island interview? A only on a different topic, (~') b 24 25 Q What was that topic?
1 Cartin 48 O 2 A It was concerning Davis-Besse. 3 Q Didn't it also concern the' issue of B&W's 4 analysis or lack of apalysis of the pumps running case f r small break loss of coolant accidents? ( 5 6 A Pumps operation during small break analyses 7 was considered, yes. g Q That[sa subject in addition to Davis-Besse, 9 right? 10 A It was a topic of discussio.n with regard 11 to a Davis-Besse issue. 12 Q When B&W studied the question of the effects (~) (m/ 13 of leaving,the reactor coolant pumps running during a 14 small break loss of coolant accident in 1977 and 1978, 15 that analysis or consideration wasn't limited just to 16 the Davis-Besse plant, was it?
- 17 MS. WAGNER: I object to the form because 18 I am not sure you have the dates rig'ht, but you 19 may answer based on whatever you think may have 20 happened.
21 A If the evaluation in question is that 22 which occurred in relationship to the Davis-Besse work i 23 project, we considered the impact of pumps on or off 24 specifically for Davis-Besse, and generically. 25 Q When you say "and generically," you mean you i
Cartin 49 1 f (~N . V 2 considered its application to all B&W plants? A That's-true. 3 4 Q' Did you say that you have reviewed the NRC typewritten notes of their interview with you? ( 5 6 A I reviewed those notes on one occasion at 7 or near the time the interview was conducted'and I have' 8 reviewed it with counsel generally. 9 MS. WAGNER: Could I just ask a clarification 10 question here? You are speaking ow of the summary 11 of those notes, io that correct, not.some - 12 notes -- (~h x/ THE WITNESS: Right. 13 14 MS.. WAGNER: The. summary which appears in i 15 the B&W material supporting the accident? 16 THE WITNESS: That's correct. 17 Q Did you make any notes on your copy of the l ' ig NRC interview of you? l 19 A No, I did not. - 20 Q Did you discuss the contents of it with 21 any ne other than counsel? 22 A I do not recall discussing it with anyone. 23 Q I am going back now to the day of the i i 24 accident and I am going to ask you some more questions 25 about your knowledge when you were in the command r i
- ., - - - . . - - ,, ,-_,r ,-=,---.n. -,.-.,,--,...-,n-.,. , . , ~ - , - - - ,,
Cartin -50 l i l O J center.- I would like you to focus on the period of 2 3 time before you got the ca'11'from the Island which gave ' 4 y u inf rmati n fr m which you concluded that there was either ongoing or that there was imminent core (, 5 6 une very. 7 Do you understand what point in time I am g talking about now, what period of time? 9 A Prior to the telephone call? 10 Q Yes. Had anybody told you, in words or s 11 substance, prior to the telephone call that there had 12 been a loss of coolant accident at Three Mile Island (' k that day? 13 14 A I do not remember the words " loss of 15 coolant accident" being used. I was informed that there 16 was a transient occurring at Three Mile Island. 17 Q Do you recall anybody saying things which
, 18 from what they said led you to conclude bsfore the 19 telephone call that there had been a loss o'f coolant 20 accident at Three Mile Island?
21 A I d n't specifically recall that, no. 22 Q Before the telephone call, do you recall 23 getting information from which you concluded that there 1 24 was a loss of coolant accident in progress at Three 25 Mile Island?
y Cartin .53 O 2 A I don't remember making any specific 4 n lusi ns as to the nature of the event prior to the 3-4 telephone call. To my knowledge, there was very little 5 data available to us. 6 Q Did anybody tell you or did you observe 7 from data that was on the blackboard in the control 8 room that the pilot operated relief valve had stuck 9 *P'"' 10 A I know now that that oc~urred during that gg event. I don't remember whether I learned that at that 12 particular morning or not. 13 Q Did y u learn before the pione call that it 14 was a possible two-phase mixture in the reactor coolant t 15 system? 16 A Prior to the phone call I had very little 17 f any data to make any conclusions as to the nature of 18 the event.
- 19 Q You mean you don't recall being told that i 20 B&W knew there was a possibility of two-phase mixture i
. 21 in the reactor vessel?
22 A No. 23 Q Do you have any recollection of anyone . 24 telling you that B&W had been informed that there were 25 high radiation readings in the dome of the reactor l
Cartin 52 1 O
~
~# building?
2 A I don't recall that, no. y 4 Q Do you recall anybody telling you before the 5 phone call that a site emergency had been declared? R( 6 A' I d n't recall whther I gained that 7 knowledge prior to or before the phone call -- I mean g prior to or after. Q Did anyone tell you before the phone call 9 10 that the reactor coolant drain tank rupture disk had 11 blown? 12 A Again, I don't recall when I came to that (~')
- s. 13 knowledge.
14 Q When did you learn that the pressurizer had 15 g ne solid? 16 A I don't specifically remember when I came 17 to the knowledge that the pressurizer had gone solid. 18 Q In 1977, was Eric Swanson your boss? 19 A Yes, he was. He was my immediate 20 supervisor. 21 MS. WAGNER: Let the record reflect that (. the witness is looking at a copy of his resume. 22 23 MR. SELTZER: Let's mark what you were f~h o4
~
looking at as GPU Exhibit 493. (_/ 25 (Copy of resume of Lucius R. Cartin marked
1 Cartin 53 2 GPU Exhibit 493 for identification, as of this 3 d' **' 4 BY MR. SELTZER: l 5 Q Is GPU 493 accurate, to the best of your 6 knowledge? 7 A To the best of my knowledge, yes. 8 Q Joe Kelly was also in your part of the 9 integration unit reporting to Eric Swanson, right? 10 MS. WAGNER: Can we have a< time frame on 11 that? 12 A At that time, yes, 13 Q In 1977 that was the NSS design group within 14 plant integration? 15 A I don't recall the specific subgroup 16 nomenclature. That was informal. 17 Q What was the general area of responsibility 18 of the group that you, Eric and Joe Kelly' operated in? 19 A The integration unit, the areas of work 20 interest varied. In general, we dealt with interface l 21 area between the B&W/NSS and the architectural engineers. L We covered special problems such as design requirements 22 23 for missiles. We prepared system requirement 24 documents. We had some responsibility for control of 25 CIS control documents. In many cases we also provided l l 4 I
- y. Cartin 54
[\
~
2 an interface between multigroups within B&W on programs that required inputs from many disciplines. 3 4 Q You are talking just about the work of swanson's group, not the overall plant integration role? ( 5 6 A That may have included some integration as 7 well. 8 Q Could you limit yourself to what I was g trying to get at which was what was Swanson's group 10 doing during the time that you were in t? 11 A I can't attest to everybody's job 12 responsibility, t 13 Q What was your understanding of what the 14 mission was of the Swanson group? 15 A Swanson's group worked basically on some 16 key areas which I have mentioned, the interface area, 17 the missile area,and we also worked on some special 18 Projects; a lot of things that required c6 ordination
~
19 of programs came in our group. 20 We also worked on sort of like unique 21 areas that weren't assigned elsewhere, like keeping up 22 with single failure, active failure criteria, passive 23 failure criteria, and again we took on sort of special Projects. ( 24 25 Q When did you join that group? 4
._-,,_____,_..__._.-._.-_r... . - _ . , , . _ _______-_,.___.-.,.--_._-.--__.-._m._____
f Cartin 55 U(~T' A In approximately 1976. 2 Q F r how long did you stay in that (roup? 3 4 A I stayed in that group until it was the unit, integration unit, was dissolved, of which a ( 5 6 reorganization occurred in approximately 1980. 7 Q Who were your immediata superiors in plant g integration over that period? 9 A My immediate supervisor was Eric Swanson. 10 The unit manager was Bruce Karrasch. , 11 Q What responsibilities does Swanson have 12 today? O) t
'~' 13 A Today Eric is*a supervisor bf a reliability analysis group. I don't know the specific name. It is 14 15 a. fairly new job.
16 Q From 1970 to 1976, your resume says that 17 you were in the ECCS unit. Is that the ECCS analysis 18 unit within the plant design section?
- 19 A Plgnt design was the name of the section for 20 a time period. The ECCS analysis unit was within plant 21 design. That unit has essentially been in existence up 22 to this year.
23 I am trying to say that it was not . 24 necessarily called plant design but the ECCS unit has 25 been essentially carried from one section name to the
1 Cartin 56 O 2 other. 3 Q You say ECCS analysis was in existence 4 until this year. Is it no longer in existence? d (' 5 A The unit name ECCS analysis has been 6 dissolved. They have combined two analysis groups, the 7 old ECCS analysis group and the safety analysis group, g and it is now called fluids and transient analysis. 9 Q Who is heading it? 10 A Mr. Bert Dunn. g 11 Q What happened to Danny LaBelle? f 12 MS. WAGNER: I object to the question.
/^% \-) 13 What do you mean " happened" to him?-
14 Q What happened to Danny LaBell'e after his 15 unit was absorbed into the combined unit that Bert Dunn 16 now has? l 17 MS. WAGNER: I also object on the grounds i
~
18 of relevhnce. l l 19 A Danny LaBelle was a previous unit manager l 20 of the safety analysis unit. He took another job 21 approximately, and this is a guess, in 1980. 22 Q Outside B&W? 23 A No, within B&W. At the present time he is
\
24 no longer with B&W. He has left the company. [\_) 25 Q Do you know what company he is now with? k.
y Cartin 57 O~ A I d not. 2 Q was Bert Dunn the head of the ECCS 3 4 analysis unit at the time you left that unit in 19767 ( 5 A Q Yes, he was. Had Dunn been the head of that unit 6 , 7 throughout the time that you were in it? 8 A No, he was not. , 9 Q Who preceded him and when did Dunn take over? 10 A I cannot give you exact dates but previous gi unit managers have been charles Parks and J. D. Carlton. 12 They were followed by Dert Dunn. 13 Q As best you can recall, wha't were your Principal assignments in the ECCS unit? ( 14 l ! 15 MS. WAGNER: At any time? l 16 MR. SELTZER: Well, beginning when he joined g7 the unit through 1976. _ 18 A In general terms I conducted lioth large 19 break and small break analyses. During that time period, 20 I Performed calculations as an analyst and also i ni
~
supervised, in the later years, supervised other . i L 22 engineers in conducting small break and large break 23 analyses. 24 Q Were the annlyses that you were conducting i 25 and supervising analyses to demonstrate compliance with
9 Cartin 58 the ECCS performance criteria in 10 CFR 50.46?
. A S,ome of the analyses were done and show direct compliance to 10 CFR 50.46 or its predecessors.
Q What other types of work did you do in the ECCS unit? 6 A We also calculated mass energy release for containment design verification. I had some but little involvement in the calculation of internal forcing functions for design of the reactor vessel internals and loop piping. In general, those are the major items. 0 Q Q Did you work on preparation of any topical reports? A Yes, I did. Q Were you listed as an author on any of the topical reports relating to loss of coolant accidents? gg A I provided input to many topicdl reports,
'I don't know exactly if my name was listed 'as an author.
g If the authors' names were listed, mine would have been on several. 21 Q Was it during the course of your employment in the ECCS unit that you got to know Bert Dunn? A Yes. 24 Om Q Did you ask to be transferred out of that I
g Cartin 59
/~% .
2 unit? A Yes. 3 4 Q Why? A I wanted to broaden my. experience. l 5 6 Q When you were assigned to plant integration, 7 did some of the areas in which you worked draw upon the g expertire that you had developed in ECCS analysis? 9 A' Yes. 10 Q Which projects specifically,that you worked 11 on in integration drew upon your expertise from ECCS 12 analysis? f r s 13 A I provided some coordination of several 14 analysis programs where there was an interface between 15 the analysis unit and the, let's say other units. 16 They included small break evaluation for bhe lowered 17 loop 177 plants, the calculation of jet impingement 18 target areas, the coordination of load ge$eration and 19 loading analysis for component design due to a LOCA. 20 Also, examining a pressurizer level issue raised on 21 Davis-Besse 1. 22 There may have been others. Those are a 23 few examples. 24 Q Are there any others that occur to you now? [O) 25 A I also provided some coordination effort
. _ . . _ - _ _ _ = _ -
3 s -
,. Cartin 60
/0. .
, in examining steam generator level requirements for the 205 plants in regard to LOCA mitigation.
3 - 1 , Q What other areas that you worked on in plant integration drew upon your ECCS analysis expertise? A During the development of guidelines and 8 the bases for the guidelines for the ATOG program, I extensively used my experience gained in ECCS. Q You worked with Joe Kelly o that? A Yes, I did. g Q Joe headed the ATOG program, right? O d 4 A That's correct. Q Was all that work done post-Th'ree Mile Island accident?
~
A The ATOG program was initiated after the accident. g Q Were all of the other programs ~that you described pre-Three Mile Island accident programs?
. A *I believe they all were pre-accident work efforts.
Q Any others that drew on your ECCS analysis g talent? A Those were the major ones, at least the 24 g larger ones.
.g Cartin 61
\
(
\l 2 Q Did you mention the reactor coolant pumps running analysis?
3 4 A That is involved with the Davis-Besse pressurizer le'el v program. ( 5 6 Q How is reactor coolant pumps running analysis 7 related to steam generator level requirements for loss g of coolant accident mitigation? MS. WAGNER: I take it you are asking how 9 10 was it in -- t 11 Q I misspoke. In this instance, how was the 12 Pressurizer level issue for Davis-Besse related to the . 13 Pumps running analysis? 14 A Davis-Besse was looking at making 15 m difications to the steam generator level control set 16 points as a means to prevent a loss of in'icated d 17 pressurizer level. The pumps running became an item 18 of discussion from the standpoint of level requirements 19 depending on the status of the pump where level is in 20 relationship to the steam generator. 21 Q So the steam generator level issue is C 22 related to the pressurizer level issue, and those two l 23 are related to the pumps running issue? l i i 24 A That is true. 25 Q Were you aware that Joe Kelly had been sent
.-nn-e- - -
-m- - . - - . , , - , - - - , , ,--,,----n- - - - - - - - - , - - , - - - - - - - , , - ,
Cartin 62 1
,m to the Davis-Besse plant after a September 1977 transient 2
to investigate the facts surrounding that transient 3 and report back to Lynchburg? 4 A I know Joe had been sent to several sites ( 5 following some transients. Whether it was that specific ) 6 transient in question, I am not sure. , 7 Q Do you recall attending a session at which 8 a group of other B&W engineers and managers were present 9 where Joe Kelly gave a presentation and described some 10 e of the principal features of a transient at Davis-Besse
~
11 plant? 12 O A No, I do not recall attending such a 13 session. - 14 Q. Do you recall attending any session at 15 which Joe Kelly made a presentation about.a particular 16 transient at which he had investigated? l 17 , MS. WAGNER: Just so we clear up the, 1 18 l record, are you including in this any meeting 19 with Joe Kelly about a transient? 20 MR. SELTZER: No, I mean one where a l l l ( 01
~
22 group of engineers and managers were in l attendance. U A No, I don't recall attending a meeting 24 l of that nature. l 25 l l l
Cartin 63 l v.i Q Is it correct that you attended a meeting 2 in or about mid-February 1978 with Bert Dunn, Bill St r e e t 3 and Cal Goslow to review some proposed guidelines which ( Dunn was formulating regarding operator handling of high pressure injection? A I do not recall attending a meeting with those particular people. Q Do you recall giving any conside' ration in February 1978 to guidelines which Dunn was drafting 10 t
; regarding the operation of high pressure injection?
MS. WAGNER: I object to the question. v I don't thin'c you have laid any foundation here 13 that this witness knows anything about it. MR. SELTZER: I am trying to ask the most
~
basic foundation question I can, which is do you give any consideration to it? A I was not assigned to work on a problem of l l that nature during that time frame. - 19 Q Are you the kind of employee who wouldn't I 21 consider something unless you are given an assignment to do something on it? 22 l MS. WAGNER: I object. ( 23 gg Q Is that the implication that. you want me l to draw from your last answer?
i Cartin 64 C\ 'V 2 A No. MS. WAGNER: Do you have another question, 3 4 Mr. Seltzer? g Did you answer my last question? l 5 6 A I said no. 7 Q Well, then your last answer was not 8 responsive to my question. 9 MS. WAGNER: I am sure the witness believes 10 he gave a responsive answer. Peqhaps you would 11 like to ask another question. 12 Q Well, if the fact that you were not assigned
'- 13 to work on it doesn't exclude the poss bility that you 14 considered it, then I would like you to a'nswer my 15 question, which is did you give any consideration in or 16 about February 1978 to the question of guidelines for 17 operation of high pressure injection?
18 MS. WAGNER: Could I have the~ question read 19 back? 20 (Question read.) 21 A I was aware at that time that there was an 22 issue raised regarding high pressure injection control. 23 My involvement there was just to the level of knowing I 24 that that was an issue at hand. I did no work to look b) 25 at what guidelines existed or if any guidelines needed
Cartin 65
, I
\
l
, to be issued to that problem.
Q Do you think that Cal Goslow was just dead 3 4 wrong when he said in his testimony that you were present at a discussion among Goslow, Dunn and Street? A I personally may or may not have attended 6 that meeting. I do not recall it specifically. 7 MS. WAGNER: I object as to your 9 characterization of whatever Goslow said. Obviously I do not direct the witness not to answer the question. Q How did you become aware that there were I (sl 13 guidelines being prepared for operation'of high pressure - injection in 1978? 1 A I was not specifically aware that any specific i 15 l guidelines were being prepared. L 16 I was aware that there was an issue raised regarding HPI operation. I was not aware in detail of what actions were being'done. Q What was.the issue which you heard had been 20 raised regarding high pressure injection operation? A 21 I was aware that Mr. Dunn was concerned l 1 22 relative to a termination of HPI flow while the reactor coolant system was saturated. l 24 I was also aware that people were working i on that issue. l 25
4 y Cartin 66 p . 2 Q Whom were you aware were working on the 3 4 A Within our unit, Joe Kelly was assigned some l ( 5 task. , 6 Q What is your best recollection as to how you 7 became aware of the work that Dunn and' Kelly were doing? 8 A At the time the task was assigned within 9 our unit, I had s discussion with Eric Swanson regarding 10 the availability of my time and whether,I had any 11 time open during that period. That particular subject 12 was raised at that time. j 13 Q As best you can recall, when was the 14 subject raised with you? 15 A To the best of my knowledge, it was following ! 16 the issuance of a memo by Mr. Dunn. 17 Q Let me show you Bert Dunn's February 9, 18 1978 memo and ask you if this is the memo'you are 19 referring to? 20 A At that time I did not see the memo from 21 Mr. Dunn. I have only seen this memo recently with 22 counsel. 23 Q In ther .f o r d s , when Karen Wagner showed you l this memo, that was the first time you had seen it? 24 25 A That is correct. l !~
Cartin 67
/~h .
(_) Q What was the assignment which you understood 2 Kelly was working on? 3 A In regard to this memo? 4 Q In regard to operator interruption of C high pressure injection. A I do not know in detail what his specific ~ assignment was, whether it was -- I was busy on some other project. Q Did you ever see Kelly's November 1, 1977 memo on the subject o,f operator interruption of high pressure injection? ( A I do not recall reading it, no. Q I am having a little difficulty with time relationship and, frankly, you are not helping. MS. WAGNER: I am going to ohject to that gratuitous comment. 18
" *** " "9" 19 1
i 20 i i 21 22 23 o4 (~)N
~
25
'l 1 Cartin 68 2 Q You say you never saw Dunn's memo until 3 preparation for your deposition yet you believe that 4
4 Swanson's discussion about whether you had availability l (' 5 or whether Kelly would work on something relating to 6 operator interruption of high pressure injection came 7 after Dunn's memo had been written. 8 What ma,kes you think it was after Dunn's 9 memo was written if you have never seen the memo? 10 MS. WAGNER: I would like to object to
- 11 your characterization.
12 MR. SELTZER: Why don't you just let him s/ 13 answer the question. , 14 MS. WAGNER: Because you are I lmplying 15 something which he has not testified to. He 16 testified this meeting came after a memorandum 17 written by Dunn. That is not the implication 18 of his testimony and I am not going' to let him 19 answer as if'it was. 20 MR. SELTZER: That is fair enough although 21 the record of many investigations is devoid of 22 any other memorandum on operator operation prior l 23 to February 9, 1978. 24 MS. WAGNER: It is what it is and there 25 are memos and this witness doesn't know anything i-
- I cartin 69 2 much about this memo.
3 Q Are you aware of a Dunn memo on operator 4 interruption on HPI that was created before the , (, 5 February 9, 1978 memorandum? 6 MS. WAGNER: I object to that question 7 because I don't think there is any evidence that 8 he knows of when the memorandum that you are 9 talking about was created. 10 MR. SELTZER: Do you adopt counsel's statemen b 11 as.true? ~ 12 THE WITNESS: That's true. D (~ 13 MR. SELTZER: And he doesnt have any 14 memory of this memo except with counsel. 15 Q Do you know what the task was that Kelly 16 was assigned to do? 17 A No. 18 Q When did you first learn that' Don Hallman 19 had asked Bruce Karrasch, the head of plan't integration, 20 to study the advisability of adopting some new 21 guidelines for the operation of high pressure injection? 22 MR. SELTZER: I object to the question. 23 You may answer it if you have a recollection 24 of such conversation. 25 A I do not know the specifics of any specific
1 Cartin 70 4 ' 2 request going.on. Most of my general knowledge regarding 3 the operator actions you are referring to was acquired 4 after TMI-2. ( 5 Q You say most of it was acquired after 6 TMI-2. Before the Three Mile Island accident, did you 7 know that Don Hallman had requested Bruce Karrasch to 8 resolve some issues relating to operator interruption 9 of high pressure injection? 10 A No. t 11 Q Since the Three Mile Island accident, have 12 you heard that Don Hallman made such a request of Bruce 13 Karrasch? 14 A If I remember correctly, I believe that was 15 part of common knowledge due to testimony in front of 16 one or more commissions. 17 Q Did you ever discuss with any,one in plant 18 integration why it took Bruce Karrasch as'long as it 19 did to respond to Don Hallman's inquiry? ' 20 A No. 21 MS. WAGNER: I object to the question. There 22 is no indication that this witness knows anything 23 about the length of time, if any. [~T 24 A No. ., \_] 25 Q Did Bruce Karrasch convene regular meetings
L 1 cartin 71 O V 2 of the people who were in the plant integration 3 section? 4 A He had frequent meetings with his supervisory engineers. He did meet with the other engineers ( 5
,6 occasionally.
7 Q Is it a fact that Bruce Karrash never 8 mentioned at any of the meetings that you had with him 9 that he had been requested to resolve an issue relating 10 to operator interruption of high pressure injection? 11 MS. WAGNER: You are now talking about - 12 these regularly scheduled meetings? (3 13 MR. SELTZER: Any meetings including the 14 regularly scheduled meetings. 15 A At that time I don't remember that being 16 an item of discussion between Bruce and myself. 17 Q Do you remember it being an item that was 18 discussed at any meeting which you attend $d before the 19 Three Mile Island accident? 20 A Would you repeat the question, please. 21 (Record was read back.) 22 A No. 23 Q During a transient, does the reactor coolant i () 24 perform a safety function? 25 MS. WAGNER: You are asking for the witness'
1 cartin 72
+ .
knowledge at or about the time of the TMI 2
- 3 accident?
4- MR. SELTZER: Right. A It depends on your definition of a safety ( 5 6 function. If you define a safety function as inventory
- 7 control, reactivity control, yes, it would contribute 8 to the successful completion of a safety function.
9 Q Isn't it a fact that the reactor coolant 10 performs an essential safety function (n achieving 11 effective core cooling? 12 A It is the medium by which you transfer heat 13 from the core to the g'enerators on a nornal operation 14 and it provides that same function during a transient. 15 Q That is a safety function, isn't it?
~
l 16 A If you want to apply that definition to 17 it, yes. . , 18 Q What work was being done,to your knowledge, 1 ( 19 within the design section in late 1978 on the issue of , 20 small break analyses with reactor coolant pumps powered? l , 21 A As a part of the considerations of l 22 pressurizer level for Davis-Besse, the small break 23 analyses with pump power, with RC pumps powered, was I~ 24 considered. D) 25 g Q Prior to B&W undertaking that analysis of i
1 Cartin 73 rs U 2 small breaks with pumps powered, Davis-Besse had had 3 some difficulties that resulted in a loss of 4 pressurizer level indication low, right? A { 5 They had problems of that nature, yes. 6 Q Now, Davis-Besse had also had problems of 7 losing pressurizer indication on the high side, too, 8 right? 9 MS. WAGNER: You are asking him if he , 10 knew that at or about this time?t 11 MR. SELTZER: Right. 12 A I don't remember having knowledge to that O 13 effect. 14 Q When is the first time you learned that the 15 Davis-Besse operators had shut off high pressure 16 injection while their system was saturated? 17 MS. WAGNER: I think the witn.ess has 18 answered this question but you can answer it 19 again. l 20 A That was the general nature of discussion 21 that I had with Eric Swanson-- I don't remember the l C. l 22 time frame--the previous problem we talked about, l 23 that Joe Kelly worked on. l j [~)
%J 24 Q Did you know that during that event the 25 operators had seen the Davis-Besse pressurizer water i
l 1 Cartin 74 2 level rise while they had a loss of coolant in progress? 3 A .I know that today. I don't believe I was 4 aware of that piece of information at that time. ( 5 Q Before the Three Mile Island accident, were 6 you aware of any event in which pressurizer water level 7 had risen during a loss of coolant accident? 8 A Not personally, no. 9 Q What about other than personally? All I am 10 asking is had it ever been brought to your attention 11 that -- 12 A No, it was not brought to my attention. (~N (_ 13 Q When you said you didn't know about it 14 personally, did you mean that you were aware that 15 other people had known of such an incident happening? 16 A I had no knowledge either myself or was 17 aware that anyone else had knowledge that_that had l 18 occurred. 19 Q Had you ever seen any ECCS andlyses done 20 at B&W before March 28, 1979 which indicated that l 21 pressurizer water level would rise when there was a l 22 small break loss of coolant accident? 23 A In general, the accidents analyzed prior [~) 24 to TMI-2, the worst cases did not give you an increase V 25 in pressurizer level of small break LOCA analyses. There
e 1 Cartin 75
~
(v~T 2 were analyses done for LOCA's let's say in conjunction 3 without a reactor trip that showed an increase in 4 pressurizer level. ( 5 Q Was this part of the ATWS program? 6 A That's true. 7 Q Before the Three Mile Island accident, were 8 you aware of any transient analysis for a loss of 9 coolant accident with the reactor tripped in which 10 B&W showed a rise in pressurizer level? 11 A Not that I am aware of. 12 Q That takes care of transient analyses which (x 13 are a particular type of analysis done with a certain 14 element of precision and computer modeling and whatever 15 else ECCS analysis does. 16 Had you ever seen any description of a loss 17 of coolant accident with the reactor tripped or 18 scrammed that predicted a rise in pressurizer water 19 level? 20 A I don't remember seeing that particular 21 phenomenon discussed. L 22 Q In any of your conversations with Bert Dunn 23 or anybody else in ECCS analysis or any of the 24 - engineering sections in uri.ts of B&W, had you ever 25 discuased before the Three Mile Island accident the
9 1 Cartin 76 .s 7"'N
- 2 occurrence of rise in pressurizer water level as a 3 result of a. loss of coolant accident with the reactor I'
4 tripped? t 5 A I do not specifically remember any ({ 6 discussions of that nature. I 7 Q You don't recall it generally either, do 8 you? 9 A No. 10 Q How did it happen that as a result of the 11 loss of level low problem at the Davis-Besse plant 12 B&W began to research the pumps powered case for small
's ss 13 breaks? *
~
1 14 A The customer specifically raised a question 15 of what is the minimum level requirement with the pumps 16 on as opposed to the pumps off for a LOCA. 17 Q Now, you are referring to the, steam 18 generators, correct? 19 A That's correct. ,' 20 Q Was it in response to that inquiry that 21 B&W discovered that it had not previously analyzed L 22 small break loss of coolant accidents with reactor 23 pumps powered? l 24 A At that time we reached the conclusion that 25 we had no documented analyses available to us as a
Q 1 Cartin 77 2 result of asking questions relative to small breaks with 3 Pumps powere.d. 4 Q You mean if any analyses had been done, 5 there was no paper record of them? ({ 6 A That's correct. 7 Q It is also correct, is it not, that as a 8 result of the Toledo Edison inquiry B&W concluded that 9 the pumps powered case could result in a worse outcome 1 10 for the reactor coolant system than the pumps off 11 case? 12 MS. WAGNER: I object to the form of the 3 r%
- 13 question.
14 A During that time frame, it was the 15 engineering judgment that the pumps tripped case was 16 the worst case of a LOCA evaluation and that engineering 17 assessments did not change at that time. . 18 Q The assessment that pumps tripped or pumps 19 off was the worst case coincided with what B&W had l l 20 previously advised the NRC, right? l 21 A That was the basic assumption made by B&W 22 and it was a general assumption throughout the industry l 23 as a whole for small break LOCA analysis, f)
%J 24 MR. SELTZER: I move to strike that as l 25 nonresponsive and would you listen to the question
( t
f 3 1 Cartin 78 (h
~ \- 2 and see if you can answer it.
3 .M S . WAGNER: I object. It was responsive. 4 (Record was read back.) ( 5 MS, WAGNER: I object to the form. 6 Q Do you understand that question? 7 A The question is confused but I will give 8 a response based on what I'think the question is. 9 Q Let me try and clear it up. B&W had 10 submitted small break topical reports to the NRC prior 11 to Toledo Edison raising the questions which Toledo 12 Edison did, right? (x '
\~s 13 A True.
14 Q Those topical reports analyzing small break 15 loss of coolant accidents contained as an assumption 16 that the worst case was a case with a loss of off-site 17 power and the reactor coolant pumps tripped, isn't , 18 that right? l l 19 A That is correct. t 1 20 Q Implicit in those topical reports was 21 B&W's conclusion that pumps running left the system in l 22 better shape than pumps off, isn't that right? Isn't i l 23 that what worst case means? 24 A By making the assumption that pumps off is l 25 the worst case, we are making the assumption that it was
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l 1 Cartin 79 (' (' 2 worse than the pumps on. 3 Q 2n other words, the system would be better 4 off if the pumps were on during a small break loss of ( 5 coolant accident? 6 A That is correct. 7 Q You were advised at or about the end of 8 1978 that B&W no longer had any assurance that pumps 9 on was a better case than pumps off, isn't that right? 10 MS. WAGNER: I object to the form of the 11 question. 12 A It was my engineering opinion formed in n N/ 13 part through discussions with personnel from ECCS that 14 Pumps off was a most conservative assumption for small - 15 break LOCA analysis. 16 Q Now, would you answer my question which l 17 was, weren't you advised at or about the ,end of 1978 18 that B&W could no longer state with assur"ance that 19 pumps on was a better case than pumps off?' 20 MS. WAGNER: I think the witness is trying 21 to answer your question but you may try again. l (_ A That may or may not have been someone l 22 i 23 else's opinion. I may have been advised of that opinion. f~h 24 Q You previously testified that B&W had no i %_] l 25 written record of any analysis of the pumps running case
- ,- -w- , y - - - - -
Cartin 80 1 2 for small break loss of coolant accidents. Isn't it 3 a fact that until B&W did'do a documented analysis of 4 the pumps running case, it couldn't be sure which was (, 5 a worst case, pumps off or pumps on? 6 MS. WAGNER: I object to the form. 7 A At that time our engineering judgment was, l 8 and it was also the judgment of other vendors within 9 the industry, that the pumps off was the worst case 10 for.small break LOCA analysis. Engine,ering judgment 11 can be and is applied in many instances. 12 Q As of the end of 1978, had you done any , s i 13 study of the position taken by competing PWR vendors 14 on pumps running versus pumps off? 15 MS. WAGNER: Are you asking for a formal 16 study of some kind? 17 MR. SELTZER: No. 18 MS. WAGNER: Just some understanding of
- 19 it? -
20 MR. SELTZER: I said a study, any kind of 21 study. 22 Q Have you examined it and if so, I want to 23 know how you did it, when you did it, what you did.
/~ 24 MS. WAGNER: At the moment, the only question C)/
25 on the record is did you make a study of it? n - , - - . - - yn, - - - , . , , , , , , . , - ,
I 14 i Cartin .8.1 A No, I did not. 2 Q So you didn't know in 1978 what other 4 vendors were doing with regard to whether pumps on or ( 5 Pumps off was a worst case,'did you? A At that time I had reviewed some submittals 6 7 by other vendors and to the best of my knowledge, those 8 all assumed the loss of off-site power and the trip of g the RC pumps. 10 Q What other vendors had you looked;at? A I don 't remember the specific reports that 77 12 I have reviewed but I have seen some documents from 13 b th Westinghouse and CE. ' Q Did you see those in 1978? Or were these 14 15 d uments y u have seen since the Three Mile Island 16 accident? 17 A I had seen -- I don't remember the exact 18 time periods that I reviewed their documents. 19 Q Are y u familiar with instances where the 20 NRC has permitted B&W to use analyses 'of another PWR 21 vendor as a substitute for a lack of B&W analyses of 22 a Particular loss of coolant transient? 23 MS. WAGNER: I object to the question. ,O A No. 24 V 25 Q Let me show you GPU 330 which is Bob Jones' s
1 Cartin 82 h '/ 2 memo to you of December 11, 1978. 3 A .I. read this. 4 Q Is GPU 330 a copy of a memorandum which 5 you received from Bob Jones on or about December 11, ( 6 1978 in the regular course o'f business? 7 MS. WAGNER: Mr. Seltzer, are you referring 8 to the entire document with everything on it 9 or just to the typewritten portion? 10 MR. SELTZER: Just to the gyped portion. 11 A Yes. 12 Q Whose handwriting is on the second page? [~h (,/ 13 A I cannot be sure but it looks very much like 14 Mr. Eric Swanson's. 15 Q Was Jones the principal engineer in ECCS 16 analysis who was working on the issues discussed in 17 GPU Exhibit 3307 18 A Mr. Jones -- I had requested of Mr. Jones 19 a memo to define resources to do an analys~is to' document 20 the position of pumps running and pumps off. This was 21 in response to my request. He was at that time a L 22 supervisory engineer at ECCS. 23 Q At the beginning of the third full (') \~) 24 paragraph, Jones said to you, "As illustrated above, 25 it is not obviously clear that leaving the RC pumps
1 Cartin - 83 2 running results in an enhanced ECCS situation."
^
3 .Did you understand from that sentence that 4 Jones was saying that it wasn't obvious that pumps (- 5 running gave a better situation than pumps off? 6 A I can't attest to what specifically 7 Mr. Jones was meaning here. Upon receipt of this 8 memo -- 9 Q That wasn't the question I asked, though. 10 I was asking whether you understood from that sentence 11 that its meaning was that pumps runn'ing was not 12 necessarily a better case than pumps off? I (~')s
\,- 13 A I do not remember that receipt of this memo 14 had a change on my understanding that the pumps off 15 was not -- was the worst case.
- 16 Q Let me try a last time. I am not asking l
17 you whether it changed your conclusions. , All I am 18 asking is your understanding of what is written here. l 19 Do you understand what I am asking for now? 20 A My understanding today? l 21 Q No, preferably your understanding in (. 22 December 1978. l 23 MS. WAGNER: Mr. Seltzer is wanting to I'T 24 know, I believe, when you received this memo, j _U 25 did you think Mr. Jones was trying to tell you
I cartin 84 rf
'- he thought pumps running was the worst case.
2 . 3 Is that correct, Mr. Seltzer? 4 MR. SELTZER: That's close but that is not it exactly. Q ( 5
.6 MS. WAGNER: Well, try again then.
7 Q Did you think that Jones was telling you 8 that pumps running could be a worse case than pumps off? 9 MS. WAGNER: He is asking for your i 10 recollection at that time, not yqur present 11 interpretation. 12 A As written, it might be one interpretation 13 but it would be contrary to the generai' understanding 14 that I had regarding Mr. Jones' position 'on the pumps 15 running issue. The intent of this memo was to define 16 resource requirements. I believe I had further
, 17 discussions with Mr. Jones upon receipt of this memo
~
18 to seek some clarification. ! 19 Q The first three words of the s'entence that l l 20 I read were "As illustrated above." When you got this 21 memo, did you understand the illustration that he 22 referred to in paragraph 27 23 MS. WAGNER: Again, Mr. Cartin, this calls 24 for your recollection of your understanding, not 25 your current interpretation of this document. y ---- . v -- p - - . - ,m-m.v,.-.- . , , . , , = - - - . - ..,,e,,,,. ,+r,
1 cartin 85
~1 .
2 A Upon receipt of this memo I believe I had 3 further discussions with Mr. Jones to understand the 4 exact items discussed within this memo. ( 5 Q Do you see the sentence that begins about 6 halfway down in the second paragraph, "It is also 7 expected that..."? 8 A Yes, I see that sentence. 9 Q That full sentence states, "It is also 10 expected that, with the RC pumps running, a ' steam 11 pocket' will not form in the cold legs and lower 12 quality fluid will exit through the break and thus (^h \-) 13 shorten the time for the system to reach the ' boiling 14 pot' mode of the transient." I 15 As an engineer, what was your understanding I 16 in 1978 of the term " lower quality fluid"? 17 A Quality is a measure of the amount of steam ,
~
18 mass as compared to the total mass of steam and water 19 within a specific location. For a computer code analysis , 20 you model these control volumes and you can define a 21 control volume for a certain space. It has an area 22 and it has a height so it has a volume. Within that 23 volume you can define a quantity called quality which l (~ v] 24 equates the pounds mass of steam divided by the total , 25 mass within that control volume.
1 Cartin 86 (- 2 Q If reactor coolant is described as having 3 lower quality flaid, it means that it has more water 4 and less steam than higher quality fluid, right? ,. 5 A .That's correct. ( 6 Q Se that if lower quality fluid will exit 7 through the break, that means a greater mass of coolant 8 is exiting, right? 9 MS. WAGNER: Greater than what, Mr. Seltzer? 10 MR. SELTZER: Greater thangif there were 11 higher quality fluid exiting. 12 MS. WAGNER: At the same rate? I think your ' 13 question is ambiguous, Mr. Seltzer. 14 If you are trying to tie it to this memorandum-- 15 MR. SELTZE R : I am not trying to tie it to 16 the memorandum. 17 Q In the context of this memorandum, when 18 Jones is saying that lower quality fluid will exit 19 through the break and thus shorten the time for the 20 system to reach the boiling pot mode of the transient, 21 he is indicating that with pumps running a greater mass L 22 of water or coolant will exit through the break during 23 a given period of time than if there were reactor
/~' 24 coolant pumps off, isn't that right?
25 A That's essentially correct, yes. He is
1 Cartin 87
'N 2 saying there is a potential to have a loss of a larger 3 amount of water as compared to steam.
4 Q And in terms of mass of water, a greater 5 mass of water would exit, right? Mass being a measure ({ 6 of molecular weight? 7 A Yes. t 8 Q So under the engineering assessment that had 9 been done up through the time when Jones wrote this 10 memo, it was the conclusion that a greater amount of 11 water or reactor coolant inventory would be lost through 12 the break if the pumps are left on than if the pumps 13 are shut off, isn't that right,7 14 A I would recognize that this was implying i 15 that there was a potential with the pumps running to 16 have a quicker loss of water mass. , , 17 Q Which is sometimes referred to as inventory,,
~
18 right? 19 A Inventory, yes. 20 Q And the water mass or inventory th'at you are 21 referring to is reactor coolant or primary coolant, (~ 22 right? Z3 A Plus whatever might be injected by safety (~*) 24 systems such as HPI.
\_/
25 Q In any subsequent conversations with ECCS
1 Cartin 88 2 personnel after receiving GPU Exhibit 330, did anyone 3 ever say that that particular.ECCS assessment was wrong? . s
- 4 MS. WAGNER: You are now speaking of this
( 5 assessment by Mr. Jones? 6 Q Yes, this assessment that water is going 7 to be lost faster through the break with pumps on than 8 off. Did a'nyone krom'CCS E ever tell you that that x 9 analysis was wrong? ' 10 A I don't remember that being discussed, 11 whether it was right or wrong. 3 12 Q Did you ever conclude that that assessment s' O~
's _/ 13 was wrong?
s 14 A' , No. ' 4 15 Q so,that if you-3 ort the reactor coolant
~
16 pumps at some point part way thr ugh the transient, you 17 would dave as's water in the syctem'than if' reactor 18 coolant' pumps had been off throughout the' transient, 19 rigNt? ) 20 MS. WAGNER: I object to the form of the T i 21 question. ' - ( s 22 ,A) That particular issue was not discussed at 23 tha't time $ Based on knowledge I have today, that is a 24 true statement for certain small breaks. ! x 25 Q And based on the!sssessment that was
, r i g
\
l -, f I ) '
1 Cartin 89
~ .
A/ 2 presented to you in GPU Exhibit 330, that would be a 3 true statement, isn't that right? 4 MS. WAGNER: I object to the form of the question as not the stated or implied substance ( 5 6 of the sentence you are referring to. 7 A The issue considered in GPU 330 was pumps 8 on or pumps off. We were not considering a pump trip 9 at any time. 10 Q Isn't it implicit from the facts presented 11 in GPU Exhibit 330 that if the pumps were tripped part-12 way through a transient, that there would be less water O)
\m 13 in the reactor coolant system than if Ehe pumps had been 14 off throughout the transient?
15 MS. WAGNER: I object to the question insofar 16 as it asks for anything other than'the witness' l l 17 recollection of what he thought when he read this 18 memo at or about the time when he received it. 19 On that basis, you may answere 20 A I do not remember considering the impact 21 of a pump trip during the course of the accident in L 22 regard to the items discussed in this memo. 23 Q You were aware, weren't you, that earlier l /~N 24 in 1978 the NRC had specifically asked B&W to consider l 25 the effects of a delayed loss of off-site power during l
1 Cartin 90. O e !
\_/ - 2 a loss of coolant accident?
3 MS. WAGNER: I object to the form of the 4 question. 5 A No, I am not aware of~that request. I do ({ 6 not remember it.
- 7 Q Let me show you a copy of a letter which 8 you got from James Taylor to Mr. Mazetis of the NRC 9 which describes exactly that question having been placed 10 before B&W by the NRC. t 11 MS. WAGNER
- I object to that characterization 12 in the absence of my reviewing the letter.
13 MR. SELTZER: I would like to mark as GPU 14 Exhibit 494, a memorandum from Mr.ITaylor to
- 15 Mr. Mazetis of the NRC dated July 28, 1978, a 16 copy to L. R. Cartin.
17 (Letter dated July 28, 1978 to Mr. G. M. l l 18 Mazetis from James Taylor marked GPU Exhibit 19 No. 494 for identification, as of this date.) 20 A I do not remember seeing this memo -- 21 MS. WAGNER: There is no question on the 22 record. 23 Q What were you about to say? (" 24 A I don't remember receiving this specific N-]/ 25 memo. I may have.
4 1 Cartin 91 (")
\#
2 Q Do you see issue 4 on the third page? 3 A Yes. 4 Q That is headed " Delayed Loss of Off-Site (' 5 Power Following a Loss of Coolant Accident." The first 6 sentence of B&W's response states, "This issue raises 7 the concern that the loss of off-site power at sometime 8 following the loss of coolant accident would result in 9 much more severe consequsnces than if off-site power 10 were lost concurrent with the loss of goolant accident 11 transient." 12 Does this refresh your recollection now
/
C_'% 13 that the NRC had in fact specifically asked B&W to 14 study the effect of a delayed loss of off'-site power 15 occurring during a loss of coolant accident? 16 A It does not refresh my memory. This issue 17 is in regard to a large break LOCA analysis as compared ,
~
18 to a small break LOCA analysis. 19 Q Well, that's interesting that'you would say 20 that. It is clear that B&W's response was only in 21 terms of a large break loss of coolant accident, right? 22 A That's correct. i-
- 23 Q And when you said that this issue is only 24 in terms of a large break, you said that because you 25 were looking at B&W's response, right?
a 1 Cartin 92 2 A That's correct. 3 Q There is nothing in the question that limited 4 it to a large break, is there? {, 5 A I presume that the question didn't come out 6 of the air for no good reason. It was asked for a given-7 reason. Probably, I would speculate, there were 8 discussions prior to issuance of the question. 9 Q You don't see anything in issue 4, subitems 10 (a) and (b), that limits it to a large, break, do you? 11 MS. WAGNER: I object to the witness 12 analyzing the document. At this time, you should 13 be asking the witness for his recollection. 14 Q You may answer. 15 A I don't remember reviewing this document l - 16 prior to today. As written, it does not make reference 17 to either a large or a small break. -
~
18 MS. WAGNER: I think it should be noted 19 for the record, since we are reading parts of it 20 in the record, that it does indicate "A study 21 was performed to assess the maximum impact of 22 a loss of off-site power (LOOP) at any time 23 following the LOCA. A minor increase in peak 1 24 cladding temperature was obtained." ( 25 Q- Now, you said that the issue as framed l l
l 1 Cartin 93 2 addressed only a large break and you said that you 3 reached that conclusion because of what was contained 4 in the third paragraph of the response. Take a look at the next page which is the last page of the response ( 5 6 to issue 4. 7 Do you see the paragraph, three paragraphs 8 from the top, it begins, "The results of the analysis"? 9 A Yes. 10 Q It states there, "The resu4ts of the analysis 11 discussed above obviously bound the effect of a loss 12 of off-site power subsequent to the loss of coolant O, 13 accident for all B&W plants."
~
14 As you understood the word " bound" as 15 applied to ECCS analyses, did you understand it to mean i 16 in 1978 that the effects of all other cases were less i
- 17 severe than the effect of the case which had been ,
i
~
18 analyzed? 19 MS, WAGNER: I take it you are asking the { l 20 witness generally what he understood the word l 21 " bound" to mean rather than what this memo meann? L_ 22 MR. SELTZER: Correct. 23 A That could be one definition for the word. l [ 24 'Q You were familiar with that use of the word l O(~T 25 " bound" as applied to transient analyses? ( i
.- , _ _ _ . _ _ _ . _ _ _ - _ _ . . .. ,,-.__,__.__,__._,_.,,o
y Cartin 93A
;( A In-general, I would have used the word 2 , " bound" to mean that your consequence would be no more
- 3 j severe on any other plant.
. 4 (Continued on the following page.) 6 1 7 1 8-1 9
- 10 (
1 l
- f 11 12 i .
l 13 i . d ! 14 , J l 15 i
- . 16 l
( 17 i l 18 19 20 21 L 22 23 24 25
J Cartin 94 1 [
%/ Does the sentence that I just read mean to 2 Q 3
y u that the analysis for a large break bounded smaller 4 breaks for all B&W plants? A I w uld say the sentence is in regard to ( 5 6 large breaks only. And just based on the contents of 7 the response. 8 Q You knew that the reactor coolant pumps 9 required off-site power in order to function, right? 10 A That's correct. t 11 Q In other words, the power requirements to 12 run the huge motors for a reactor coolant pump couldn't eg ( 4 .
'l 13 be supplied by emergency diesel power at the nuclear plant itself? I 14 15 A That's true.
16 Q So if power from sources beyond the nuclear 17 plant was not available, then the reactor, coolant pumps
~
18 would shut off?
. 19 A In general that is a true s t a t 'e m e n t , yes.
20 Q To be correct, it is true whenever there is 21 n t power available from the nuclear power plant itself, 22 right? 23 A I cannot attest to the actual availability of power at any one site. The assumption for analysis (v~) 24 25 purposes is generally for loss of off-site power. The
4 1 Cartin 95 O 2 pumps trip and your power is.being supplied by the 3 emergency diesels only. 4 Q What is your understanding, if any, as to ( 5 why you were marked for a copy of' Taylor's July 28 6 letter to the NRC, GPU Exhibit 494? 7 A Today I don't know why. O Q Did the subject matter of GPU 494 relate 9 to any of your responsibilities during 19787 10 MS. WAGNER: Do you mean this specific work 11 or generally the notion of LOCA analysis? I mean, the subject matter of this memo I,think is a LOCA 13 analysis which I think Mr. Cartin testified he 14 had something to do with. That is what you mean? 15 MR. SELTZER: Yes. , 16' A Before I answer your question, I would like
- 17 to review.the other items and their conten'ts.
18 MS, WAGNER: Does your question relate to 19 everything in the memo or were you trying to 20 direct the witness' attention? ! 21 MR. SELTZER: I think it would shorten it
~~
if with respect to issue 4 you can see matters 23 raised there that we're pertinent to your 24 responsibilities in 1978, I would be satisfied 25 with that.
~
i.
--w-w---=s c- -e-- ,,yy+g.s em wg-w-y .-gwy9- ry,w w -w~m-mw ,- y-,9wrg-rw -%r-y-e--=--e- e, 9,-* -.e-+me- -mtwwi--y-1-wp,~e-w-o-, gen a c -
Cartin 96 1 O ki' A In 1978, I would have not prepared or 2 Pr Vided input to this response in regard to the impact 3 on large break LOCA analysis. The only item that may have 4 been a topic would have been WASH-1400 and a probability. 5 I maintained those documents at my work station so I 6 may have looked up a number for somebody. 7 8 Q Y u were doing work on small break loss of g coolant accidents in 1978, is that right? A I was doing some interface. work, yes. 10 gy I did not perform an analysis at tliat time. 12 (Recess taken.) 13 Q Y u knew before the Three Mile Island accident that the NRC requires vendors to assume a loss 14 f ff-site power and a consequent reactor coolant pump 15 16 trip occurring at whatever would be the worst time in 17 any transient, isn't that right? , 18 MS. WAGNER: I object to the form. 19 A It was a. general anlysis practice at least 20 within B&W to look at cases with and without a loss of
,31 off-site power. In general, a loss of off-site power
~
C was postulated following reactor trip which corresponded 22 23 to the time where that was most probable.
- Q Didn't you'know before the Three Mile Island 24 25 accident that in addition to postulating a reactor trip ll
g Cartin g7 2 due to loss of off-site power at the start of the transient, the NRC was also requiring that B&W consider 3 4 reactor trip at whatever would be the worst time for the ( 5 transient? 6 MS. WAGNER: I object to the form.- A I don't remember that being a conclusion on 7 8 my part. g Q. Well, isn't that something that had already 10 been required for accidents other thanta loss of coolant it accident, such as a steamline break or a loss of main 12 feedwater? 13 MS. WAGNER: Are you now asking about the 14 effect of RC pump trip on those events? Is that 15 right? 16 MR. SELTZER: RC pump trip and loss of 17 off-site power. Let me restate the, question. 18 Q You knew before the Three Mild Island 19 a'ccident, didn't you, that the NRC had bee'n requiring 20 B&W to assume a loss of off-site power and an 21 accompanying reactor coolant pump trip at the worst L p int of a transient, and had required that for steamline 22 23 breaks, loss of main feedwater, feedwater mainline break, 24 et cetera? %..) 25 MS. WAGNER: I object to the form.
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g Cartin 98 m 2 , A I know at some time I reached that en lusion. I believe, if my memory serves me correctly, 3 it occurred at a time after TMI-2 when we were considering 4 (; 5 perator actions to trip the pumps as. opposed to 6 attempting to justify the pumps would continue to run and 7 there would be a low probability a pump trip would occur 8 during a small break LOCA. 9 Q - You said you reached that conclusion after 10 the Three Mile Island accident when yot; were developing 11 operator guidelines. Isn't it a fact that you reached 12 that onclusion based on a review of what assumptions O / C/ 13 the RC had required during periods that preceded the 14 Three Mile Island accident? < 15 MS. WAGNER: I object to the form. 16 A My general involvement in accident analysis 17 prior to TMI-2 was basically restricted to LOCA. I 18 have done some review but not in depth of'the accident analyses assumptions on other non-LOCA events. 19 , 20 Q Let me try and take it in smaller steps. 21 You said after the Three Mile Island 22 accident, you reached a conclusion that the NRC had been 23 requiring an assumption of loss of off-site power A tripping the reactor coolant pumps at whatever was the 24 25 worst time for the transient, right? I
g Cartin as O' 2 A I remember reviewing that particular item 1 3-after TMI-2, ,yes. 4 Q And you reached that conclusion after the "I~ ** d*"** # 9 ( 5 A That's correct. 6 7 MS. WAGNER: Could I ask a clarifying g question? I think the witness is a little 9 e nfused. 10 .Are you telling Mr. Seltzer that you _gg reached such a conclusion or are you telling him 12 you think the NRC had such a requirement? (N/ THE WITNESS: I believe tha't a requirement 13 4 14 existed within the SRP's of pump trip at a worst 15 time be considered for some non-LOCA events. l 16 Q SRP's are the NRC Standard Review Blan, right? 17 A That's correct. 18 .Q And those SRP's requiring the' assumption i . 19 of pump trip at the worst time had been in~ existence 20 before the Three Mile Island Un'it 2 accident, right? l A Yes. 21 L 22 Q The Standard Review Plaa is an NRC guide j 23 that explains how the NRC will apply the general design 24 criteria and Appendix K and 10 CFR 50.46 to transient 25 analyses, is that right?
1 Cartin 2.Q a v 2 A It can be viewed as doing that. The SRP's 3 are a regulatory guide that identify what has to be 4 considered within the final safety analysis report. (' 5 Q Y u say that the SRP requiring that B&W 6 consider reactor coolant pump trip at the worst time 7 during a transient existed in the NRC standard review plan I g prior to the Three Mile Island accident. If that is the 9 case, why didn't B&W, if you know, assume a reactor 10 coolant pump trip at whatever would be(the worst time 11 during a small break loss of coolant accident when that 12 analysis was being reviewed in. late 19787 , O 13 A That was a requirement for non-LOCA events. 14 I don't believe it. exists in the SRP specifically 15 relating to loss of coolant accidents. 16 Q Have you ever discussed with anybody l 17 whether the requirement for assuming loss.of off-site 18 power at the worst time during a transient applied only l 19 to events other than a'LOCA? < 20 MS. WAGNER: At any time? I 21 Q First, did you ever discuss it before the kJ 22 Three Mile Island accident with anyone? 23 A I do not remember discussing it prior to the ()- 24 accident. We had some discussions post-accident. 25 Q With whom did you discuss it after the l l *
,, . . . , _ _ ~ , , , , - , - _ _ . , _ , . . _ . - _ . . _ _ _ _ _ _ _ _ . , - . . . ~ - _. . ~ _ _ . _ . , _ _ . , _ . _ _ _ _ _ _ _ _ _ , _ _ . , _ _ _ _ _ _ _ _ _
Cartin 101
, [
i V, accident? 2 4 A I don't remember individuals, specific individuals. I just remember looking at that particular 4 issue and formulating a recommendation to do a manual RC pump trip. 6 Q It' is a fact, isn't it, that you concluded 7 8 after the accident that the NRC will require the assumptiqn
,g of a reactor coolant pump = trip at the worst-time during a loss of Coolant accident because that would be g consistent with their position for non-loss of coolant
- d*"*"# ~
12 l 13
~
g do you mean the NRC will? From now on? i A It was my opinion that that would be a 15 Probable position for the staff to take. 16 g Q The staff of,the Nuclear Regulatory i 18 Commission? ~ g A That's correct. - g Q And you expressed that position in writing 1 after the accident, didn't you? 21 L A I believe I have seen a memo to that effect. 22 ( g I don't remember exactly what memo it is. Q A em by you, right? 24 I . A Yes. i 23 i l
1 Cartin 102 i
\
2 Q Before the Three Mile Island accident, you 3 never told a_nybody that they should anticipate that 4 the NRC will require assumption of loss of off-site ( 5 power and reactor coolant pump trip during a loss of 6 coolant accident, did you? 7 MS. WAGNER: I object to the form of that. 8 THE WITNESS: Would you repeat that, please. 9 (Record was read back.) 10 A Prior to the accident, we gssumed a loss 11 of off-site power and pump trip coincident with a , 12 reactor trip for all small break LOCA analysis. I do 1 (~~s
\m/ 13 not remember discussing the requirement to have a pump i
14 trip at any time. 15 Q Do you recall discussing the fact that the 16 NRC will require B&W to assume a pump trip at the 17 worst possible time during a transient? 18 MS. WAGNER: I object to the form. 19 A Not prior to TMI-2. - 20 Q Let me show you what has previously been 21 marked as GPU 122 which is a memo from you to R. C. 22 Luken dated December 19, 1978, Is GPU 122 a copy of 23 a memorandum which you circulated at B&W on or about (~S 24 December 19, 19787
\_)
25 A Yes,
1 Cartin J03
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(~~)
/ 2 g Would you take a look at item 6 on page 2.
3 That item re,fers to the same issues raised by Jones 4 in GPU 330, right? i A (. 5 Yes, they are related. 6 Q In item 6, you wrote, "B&W's position to 7 Toledo Edison Company is that the status of the reactor 8 coolant pumps should'not be included in the duai set 9 point control logic at this time. If questioned by the 10 NRC, however, B&W must be in a positiop to state that 11 the small break topicals have been considered the worst 12 possible conditions (i.e., lo'ss of off-site power). (~)) s_
- 13 Our inability to respo,nd conclusively Eo'such an inquiry 14 could result in the NRC derating or shutting down all 15 of B&W's 177 fuel assembly operating plants (exc ep t 16 SMUD} until the issue is resolved."
17 What was it about this issue which you 18 thought could lead to the NRC derating or' shutting down 5 l 19 all of B&W's 177 plants? ' l 20 A At this point in time, our' engineering 21 assessment was that the pumps tripped was the worst L 22 case. This was the general assumption made in all of 23 our past analyses. During our review for Davis-Besse, 24 we generally agreed with that position, 25 With regard to this particular memo at this
l 1 Cartin 104
\- time, I was of'the opinion that we needed to do an 2
3 analysis and. document that assumption which was a h 4 pretty basic assumption for all of our small break ( 5 nalysis. I was basically saying to stand up and 6 conclusively prove that assumption would require a 7 detailed analysis using computer codes. 8 I felt that our engineering judgment was g right but it was in our best interest to document that 10 analysis and have it in the file until tthe issue was
/t .
11 raised with the staff and they could decide to disagree 12 with our engineering opinion until an analysis was 13 done. The worst possible thing they coul'd do was 14 possibly derate the plants -- 15 Q Or shut them down? j- 16 A Or shut them down. Let's avoid any 17 possibility of this and perform this additional analysis 18 and the recommendation made here is that ~we should do
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19 that and it was done fairly quic?cly. i 20 Q When was it done? 21 A The analyses were started in January of ( l 22 '79. 23 Q Why did you say, "The customer should not ( 24 be informed of the ECCS analysis efforts to examine the J a 25 pumps running case"? 1
1 cartin 305
.0 2 A This is really a poor choice of words.
3 The intent h.ere, the customer was aware of the 4 assumptions made in his past LOCA analyses. He was , informed that no documented computer code calculations ( 5 6 existed for pumps running assumptions. My , intent here w 7 was let us formulate the scope of analysis to be 'd o n e , i 8 secure thi funding in house adid be in a gooc posiLien 9 to inform the c.ustomer specifically what we are going'
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10 to do at sometime in the future. t 7 11 It was really not good practice to-tell 12 the customer that"We are thinking about doing this 13 analysis and when we get around to it, we'will tell 14 you." I was trying to make the point, let's get our 15 plan developed, funding secured, scheduling developed 16 and that would be an. appropriate time to tell the 17 customer exactly what our plans were. 18 Q When did it first occur to B&N, to your i 19 knowledge, that you would not have a comp 1~ete analysis 20 of the pumps running case until you had assumed loss 21 of off-site power at the worst possible time during a
/
\m 22 transient?
23 MS. WAGNER: Objection to the form. 24 A I believe the issue of pumps tripped at 25 any time during the small break accident was raised 1
--,---,c--..--..-n. ,,----------,,.,.-,.---+-,.n-,--,- n-~ ,--.-n., .----.-,,n.----.--n--,,, . - , - , , , ,
1 Cartin 3 06 y- - 2 after TMI-2 as a result of a PSC. 3 Q .Is that the PSC initiated by Charles 4 Parks? (, 5 A I believe Mr. Parks initiated it. I don't 6 know the PSC number. 7 Q Let me show you GPU 282 which is the PSC 8 that I am familiar with, relating to small break analysis 9 with no loss of off-site power. 10 Is this the PSC to which you itere referring? 11 A Yes. 12 Q Does this PSC indicate thet Br.W was going
\_/ 13 to study the effect of a loss of off-site power at 14 whatever would be the worst time during a small break 15 loss of coolant accident?
e 16 MS. WAGNER: Could I hear that again? ! 17 (Record was read back.) , 18 A This PSC essentially identifies the potential 19 that a pump trip during the event can lead to a violation 20 of the accepted criteria as defined in 10 CFR 50.46.
, 21 The bottom line recommendation was to trip the pumps
\m .
22 as opposed to doing the analysis. As written in this 23 PSC, B&W did do an extensive Enalysis upon the ! .24 impact of a trip. Whether it was the result of this [)h 25 PSC or not, I don't know.
y Cartin J07 [ 2 Q This PSC you say indicates the potential
-3 for a situation to be worst for a pump trip during the 4 transient than if the pumps are tripped at the start of
(' 5 , the transient, right? 6 A Yes. , 7 Q And do you see the box on the second page 8 of the exhibit with the indistinct number 2 in the 9 upper left-hand corner? 10 A Yes, t 11 Q Are you familiar with PSC forms enough to 12 know that what is part of the form there says when, / [N/ f 13 how and on which plant was the safety concern identified?( 14 A Yes. *
/
15 Q Am I correct that this PSC indicates that
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16 this safety concern was identified in January 19797 s-
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17 A This indicates that the analysis was done i I . 18 then. The PSC was issued in May of '79. 19 Q Since this is an area that you' were 20 following on behalf of plant integration, do you know 21 of any reason why it took B&W from January 1979 to May 22 1979 to formulate a PSC and study this problem? 23 MS. WAGNER: I object to the question. ID 24 I don't believe that the facts you have put
\)
25 together in that question were testified to by
I Cartin Ja8 (~)
~
\/ 2 this witness nor'does that conclusion you draw 3 from this document. I don't think the witness 4 should answer the question.
(, 5 Q Isn't it a fact that within plant integration 6 you were the engineer who was assigned to follow this 7 issue of small break loss of coolant accident with its 8 subsidiary issue of loss of off-site power? 9 MS. WAGNER: At any time? 10 MR. SELTZER: During 1978 and 1979. 11 A While in plant integration, I was assigned 12 an effort to provide some interface activity in regard (~)
'(_/ 13 to a Davis-Besse issue of which that particular issue 14 on Davis-Besse pumps running versus pumps tripped was i
15 considered. My involvement with that program -- my 16 involvement with the issue terminated at the completion 17 of that program prior to-TMI-2. . 18 Q At which point it revived, correct? l 19 A That's correct. ' 20 Q So you were involved in interfacing on this 21 issue in the December '78, January '79 period and then 22 you were involved again in the period immediately after 23 Three Mile Island Unit 2, right? l ('}
\/
24 A That's correct. 25 Q Let me put the question to you again that I
I 1 Cartin 109 r% - N_A 2 put to you a minute ago. Do you know of any' reason 3 why it took S&W from January 1979 to May 1979 to formulat e 4 a preliminary safety concern based on the issue of pumps 4 ( 5 being tripped during a small break loss of coolant 6 accident? 7 MS. WAGNER: I obj ect to the question 8 because I don't think there is any evidenco 9 either from this witness' test'imony or any other 10 evidence that something happenedtin January '79 T 11 which should have resulted in a PSC. 12 I just don't understand your question. ("
\-
13 MR. SELTZER: I am not going to try and 14 convince you because box 2 says this PSC was i
,15 generated because of something that happened 16 in January of 1979.
17 Q So you may answer the question, Mr. Cartin. 18 MS. WAGNER: I don't want Mr. Cartin to l l l 19 answer this question based on any as' sump tion s 20 he makes about this document. i
. 21 If you have a recollection that some issue k.
22 was raised in January and became a PSC in May, 23 which is something you knew about, you can i certainly discuss that with Mr. Seltzer. ( 24 i 25 Do you understand the question at this i t
1 1 Cartin 110
'^#
, 2 point?
3 .THE WITNESS: Repeat the question. 4 (Record was read back.) ( 5 MS. WAGNER: I am going to direct the 6 witness not to answer the question unless you 7 establish that he understands that that was a 8 factual situation which he was aware of. 9 Q Is that a factual situation of which-you g 10 were aware? e 11 MS. WAGNER: A factual situation, the premise . 12 of your first question? [")N (_ 13 MR. SELTZER: Right. 14 MS. WAGNER: Do you remember that question? 15 THE WITNESS: I don't really know what the 16 question is. Would you rephrase the question? 17 Q The question is, why did it take B&W from
~
18 January 1979 when the issue was first identified to 19 May 1979 to formulate a PSC about this iss'ue of pumps 20 being tripped during a small break loss of coolant
, 21 accident?
L 22 MS. WAGNER: And I am going to direct the 23 witness not to answer that question unless you 24 establish that he understands that that was the 25 fact.
1 Cartin its ( 2 Q Now, the question was, did you understand 3 that was the fact, that it took B&W from January 1973 4 to May 1979 before they identified a PSC, a preliminary ( 5 safety concern relating to pumps tripped during a small 6 break loss of coolant accident? 7 MS, WAGNER: Did you understand that that 8 was an issue that should have been raised in 9 January and wasn't raised until May? ' 10 A No, I didn't understand tha,t an issue to 11 be raised. My only point of knowledge here is that the 12 PSC that.was written was based on a previous analysis t .
-\- which just so happened to be four or five months 13 14 previously. I really have no knowledge of why the 15 conclusion took four months to be reached.
16 (Time noted: 4:45 p.m.) 17 - 18 19 . Lucius Roscoe Cartin 20 Subscribed and sworn to before me i 21 this day of 1982.
- 22
! 23 24 25 i -
I 112 O-v 2 ggRggFggggE 3 STATE OF NEW YORK )
- ss.:
4 COUNTY OF NEW YORK ) ( 5 6 NANCY A. RUDOLPH I, , a 7 Notary Public within and for the State of New York,
,8 do hereby certify that the foregoing deposition 9 of LUCIUS ROSCOE CARTIN was taken before 10 me on Tuesday, April 13, 1982 E
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11 That the said witness was duly sworn 12
.before the commencement of his testimony and v
13 that the within transcript is a true-record of said 14 testimony;
- 15
, That I am not connected by blood or 16 marriage with. any of the parties herein nor 17 interested directly or indirectly in thd matter in 18 controversy, nor am I in the employ of any of the 19 counr31.
20 IN WITNESS W2RNOF, I have hereunto set 21 ({ ss my hand this 'I . ' day of Aoril , 1982, 22 03 in ;<.-c a , kl , bY , b ' ~ NANCY'A. RUDOLPH f' 25
7 l 133 O IND EX WITNESS PAGE Lucius Roscoe Cartin 3 EXH IB ITS i .. i GPU l j NUMBER FOR IDENT. 492 Diagram 35 t. 493 Copy of resume of Lucius R. , Cartin , 52 i 494 , Letter dated July 28, 1978 L to Mr. G. M. Mazetis from James Taylor 90 O O 5 O m--m.,-,.e,m.,sn.,.m.meem,..,,,,,.e,,,,n,,__,,,-,om,_ _ ,_,,,,,y__,..w,avw_., w., ,,,, y,,,p n mg_,, ,y,,., ,,, q,-w w.,_,-n -- - -}}